NRC Generic Letter 1977-02

NRC Generic Letter 1977-002: Nuclear Plant Fire Protection Functional Responsibilites, Administrative Controls and Quality Assurance

ML031280293
Person / Time
Issue date:	08/04/1977
From:	Reid R Office of Nuclear Reactor Regulation
To:	William Cahill Consolidated Edison Co of New York
References
GL-77-002
Download: ML031280293 (23)

W

DISTRIBUTION:

August 4, 1977 Docket File (3 NRC PDR (3)

50-3 L PDR (3)

Dockets Nos.:

50-247 RReid and 50-286 RIngram PErickson TCarter TWambach Consolidated Edison Company Attorney, OELD

of New York, Inc.

OI&E (5)

ATTN: Mr. William 3. Cahill, Jr. DEisenhut Vice President TBAbernathy

4 Irving Place JRBuchanan New York, flew York 10003 ACRS (16)

Gray File (3)

Gentlemen:

RE: INDIAN POINT UNITS NOS. 1, 2. AND 3 We are enclosing for your infonaation and use a copy of

• Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls and Quality Assurance.* This document is presently being used by the HRC as supplemental guidance for the review of the organizational and adfvninistrative aspects of the fire protection evaluation of your facility.

By letter dated July 15, 1977, you indicated your intention to develop no fire protection Technical Specifications for Indian Point Unit No. I because it was shutdown and defueled. Ie, there- fore, request that you propose fire protection Technical Specifi- cations for Indian Point Unit No. 1 appropriate to Its present shutdown defueled condition. A fire originating in Unit No. 1 could have serious consequences at the operating units because of their close proximity to Unit No. 1.

Sincerely, Robert W. Reid, Chief Operating Reactors Branch #4 Division of Operating Reactors Enclosures Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls f1'u 1 A

and Quality Assurance bpva~- jORB#4:DOMJORB#l ~~ >3T O

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1676-626424AT*j

Consolidated Edison Company of New York, Inc.

cc: Mrs. Kay Winter, Librarian Hendrick Hudson Free Library

31 Albany Post Road Montrose, New York 10548 Leonard M. Trosten, Esquire LeBoeuf, Lamb, Leiby & MacRae

1757 N Street, N. W.

Washington, D. C. 20036 Anthony Z. Roisman , Esquire Berlin Roisman & Kessler

1025 lAth Street, N.W., 5th Floor Washington, D. C. 20005 Paul S. Shemrin, Esq.

Assistant Attorney General State of New York Department of Law Two World Trade Center New York, New York 10047 Sarah Chasis, Esq.

Richard M. Hall, Esquire

15 West 44th Street New York, New York 10036 Director, Technical Development Programs State of New York Energy Office Agency Building 2 Empire State Plaza Albany, New York 12223 Admiral Paul Early (IP-3)

Power Authority of the State of New York

10 Columbus Circle New York, New York 10019

I *

~ . -

NUCLEAR PLANT FIRE PROTECTION FUNCTIONAL RESPONSIBILITIES, ADMINISTRATIVE

CONTROLS AND QUALITY ASSURANCE

The functional responsibilities, administrative controls, and quality assurance related to nuclear power plant fire protection programs have a significant role in preventing and fighting fires. Because these controls represent a significant portion of the licensee's fire protection program to and are subject to periodic reviews by NRC inspectors, it is necessary have a common understanding between applicant/licensees, NRC reviewers, and NRC inspectors as to what constitutes adequate delineation of respon- sibilities, administrative controls and quality assurance and how these responsibilities and activities should be conducted. Therefore, supple- mentary guidance on these controls is desirable.

Appendix A to Branch Technical Position 9.5-1 and Regulatory Guide 1.120

provide overall guidance related to functional responsibilities, admin- istrative controls, and quality assurance. The discussion in the Attach- ments provides supplemental guidance on specific functional responsibilities, administrative controls, and quality assurance necessary to assure an effective fire protection program. The table below correlates each subject for which supplemental guidance is provided with the respective section(s)

of Appendix A and Regulatory Guide 1.120.

REGULATORY

SUBJECT APPENDIX A GUIDE 1.120

1. Fire Protection A.1, B, C C.1, C.2, C.3 Organization

2. Fire Brigade A.l(d), B.5 C.1(4), C.2e Training

3. Control of B.2, B.3(c) C.2.b, C.2.c(3)

Combustibles

4. Control of Ignition B.3(a) C.2.c(1)

Sources

5. Fire Fighting A.l(d), B.1, 4, 5 C.la(4), (5),

Procedures C.2.a, d, e.

6. Quality Assurance C. C.3

I

-2- This supplementary guidance is to be given to utilities and is being distributed to NRC fire protection program reviewers and NRC Office of Inspection and Enforcement.

The licensee should provide the description of fire protection functional responsibilities and administrative controls in a fire protection plan which describes his organization and its qualifications, fire brigade training, the controls over combustibles and ignition sources, methods for assuring the availability of the fire protection systems and equip- ment; procedures for fighting fires, fire watch, and quality assurance provisions for the fire protection program. The plan should also identify the plant procedures that implement the plan. The plan will be filed with the Nuclear Regulatory Commission and the plant procedures should be available to NRC Inspectors and at the plant site.

Attachment No. 1 FIRE PROTECTION ORGANIZATION

communication per-

1.0 The organizational responsibilities and lines of the various be defined between taining to fire protection should and functional positions through the use of organizational charts responsibilities. As a minimum the descriptions of each position's should be positions/organizations responsible for the following designated:

which has management a. The upper level offsite management position and assess- responsibility for the formulation, implementation, nuclear plant fire protection ment of the effectiveness of the program.

responsible for b. The offsite management position(s) directly assessing the

(1) formulating, implemenring, and periodically program for the licensee's effectiveness of the fire protection drills and training con- nuclear power plant including fire plant personnel. The results ducted by the fire brigade and level be reported to the upper of these assessments should with management position responsible for fire protection actions as recommendations for improvements or corrective deemed necessary.

guidance to dev-

(2) Using the following NFPA Publications for elop the fire protection program:

No. 4 - "Organization for Fire Services"

No. 4A - 'Organization of a Fire Department"

No. 6 - "Industrial Fire Loss Prevention"

No. 7 - "Management of Fire Emergencies"

No. 8 - "Management Responsibilities for Effects of Fire on Operations"

No. 27 - "Private Fire Brigades"

for the overall c. The onsite management position responsible administration of the plant operations and emergency plans which include the fire protection and prevention program and which control and contact for all contingencies.

provides a single point of

'-

2 which:

d. The onsite position(s)

to: minimize the amount

(1) implements periodic inspections areas; determine the of combustibles in safety related practices; assure the avail- effectiveness of housekeeping of all fire protection ability and acceptable condition breathing apparatus, emergency systems/equipment, emergency fire stops, penetration lighting, communication equipment, and assures prompt and seals and fire retardant coatings;

corrective actions are taken to correct conditions effective and preclude their recurrence.

adverse to fire protection operating fire fighting training for

(2) is responsible for the the plant's fire brigade; design and personnel and plant inspection and testing of selection of equipment; periodic with fire protection systems and and equipment in accordance and deter- evaluate test results established procedures systems under test.

mine the acceptability of the of all fire drills to determine

(3) assists in the critiqueobjectives have been met.

how well the training identify proposed work activities to

(4) reviews and evaluatesfire loads.

potential transient indoctrination of all plantpro-

(5) implements a program for administrative contractor personnel in appropriatefire protection program, .

cedures which implement the relative to fire protection.

and the emergency procedures on the for instruction of personnel

(6) implements a programaccidental leaks or events such as proper handling of that are related to fire spills of flammable materials protection.

for fire protection quality e. The onsite position responsible assurance.

for assuring the effective This position should be responsibleprotection program by planned in- of the fire implementation He should assure and verify spections and scheduled audits. or audits are promptly re- that results of these inspections personnel.

ported to cognizant management

3 f. The positions which are part of the plant fire brigade

(1) The plant fire brigade positions should be responsible for fighting fires. The authority and responsibility of each fire brigade position relative to fire protection should be clearly defined.

(2) The responsibilities of each fire brigade position should correspond with the actions required by the fire fighting procedures.

(3) The responsibilities of the fire brigade members under normal plant conditions, should not conflict with their responsibilities during a fire emergency.

(4) The minimum number of trained fire brigade members avail- able onsite for each operating shift should be consistent with the activities required to combat the most significant fire. The size of 'tefire brigade should be based upon the functions required to fight fires with adequate allow- ance for injuries.

(5) The recommendations for organization, training, and equip- ment of "PRIVATE FIRE BRIGADES" as specified in NFPA

No. 27-1975, including the applicable NFPA publications listed in the Appendix to NFPA No. 27, are considered appropriate criteria for organizing, training, and operating a plant fire brigade.

2.0 Qualifications a. The position responsible for formulation and implementation of the Fire Protection Program should have, within his organ- ization, or as a consultant, a Fire Protection Engineer who is a graduate of an engineering curriculum of accepted standing and who shall have completed not-less than six years of engineering attainment indicative of growth in engineering competency and achievement, three of which shall have been in responsible charge of fire protection engineering work. These requirements are the eligibility requirements as a Member in the Society of Fire Protection Engineers.

4 b. The fire brigade members qualifications should include satis- factory completion of a physical examination for performing strenuous activity, and of the fire brigade traininadescribed in Attachment No. 2.

c. The personnel responsible for the maintenance and testing of the Fire Protection Systems should be qualified by training and experience for such work.

d. The personnel responsible for the training of the fire brigade should be qualified by training and experience for such work.

ALs.'hment No. 2 FIRE BRIGADi TRAINING

to fight potential assure that the capability The training program should The program should consist of an and maintained. classroom fires is established program followed by periodic initial classroom instruction fire fighting and fire drills:

retraining , practice in

1.0 Classroom Instruction instruction should include:

a. The initial classroom types fire hazards and associated

(1) Identification of the in the plant, and an identi- of fires that could occur of such hazards.

fication of the location equip- location of fire fighting

(2) Identification of the and familiarization with layout ment for each fire area, and egress routes to-each of the plant including access area.

and use of available fire fighting equipment,

(3) The proper The each type of fire.

the correct method of fighting include electrical fires, types of fires covered should trays, hydrogen fires, flam- fires in cables and cable fires, and record file fires.

mable liquid, waste/debris fire fighting plan with

(4) Indoctrination of the plantindividual's responsibilities.

specific coverage of each lighting, ventilation

(5) The proper use of communication, and emergency breathing equipment.

of the fire fighting

(6) The direction and coordination leaders only).

activities (fire brigade of expected products of

(7) The toxic characteristics combustion.

fighting fires inside buildings

(8) The proper method for and tunnels.

procedures and procedure

(9) Detailed review of fire fighting changes.

and changes in fire

(10) Review of latest plant modifications fighting plans.

2 qualified individuals should be provided by in fighting b. The instruction experienced, and suitably trained and in using knowledgeable, could occur in the plant the types of fires that available in the nuclear power plant.

the types of equipment Leaders

"Fire Protection Staff" and Fire Brigade Members of the may conduct this training.

brigade members should be provided to all fire c. Instruction and fire brigade leaders.

repeat planned meetings held every 3 months should year period.

d. Regular program over a two the classroom instruction

2.0 Practice on the should be held for fire brigade members mag- Practice sessions fighting various types of fires of similar occur in proper method of as those which could and difficulty brigade members nitude, complexity, These session: should provide of em- a nuclear power plant. the use fire extinguishment and with experience in actual under strenuous conditions.

These but not ergency breathing apparatus at regular intervals be provided practice sessions should each fire brigade member.

to exceed 1 year for that the

3.0 Drills in tne Plait%. -- .

fire brigade drills should asbe aperformed team. Drills should include the fire brigade can practice following:

required to notify of fire alarm effectiveness, time and use of a. Assessment and selection, placement and assembly fire brigade, equipment.

his role in the fire Assess each brigade member's knowledge of to contain the fire.

b. for the area assumed strategy plant fighting the brigade members conformance with established equipment, Assess and use of fire fighting fire fighting procedures emergency breathing apparatus, communi- including self-contained and ventilation equipment, to the extent cation equipment, practicable.

3 c. 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 be varied such that brigade members are trained in fighting fires in all safety related areas containing significant fire hazards. The situation selected should simulate the size and arrangement of a fire which could reasonably occur in the area selected, allowing for fire development due to the time required to re- spond, to obtain equipment, and organize for the fire, assuming loss of automatic suppression capability.

d. Assessment of brigade leader's direction of the fire fighting effort, as to thoroughness, accuracy, and effectiveness.

e. The drills should be performed at regular intervals but not to exceed 3 months for each fire brigade. At least one drill per year should be performed on a "back shift" for each fire brigade. A sufficient number of these drills, not less than one for each fire brigade per year, shall be unannounced, to de- termine the fire readiness of the plant fire brigade leader, brigade, fire protection systems and equipment.

f. The drills should be pre-planned to establish the training objectives of the drill. The drills should be critiqued to determine how well the training objectives have been met.

Unannounced drills should have their critiques performed by members of the management staff responsible for plant safety and security. At three year intervals, drills should be critiqued by qualified individuals independent of the utility's staff.

4.0 Records

, Records of training provided to each fire brigade member including drill critiques should be maintained to assure that each member receives training in all parts of the training program. These records of training should be available for review.

" Attachment No. 3 CONTROL OF CU;IBUSTIBLES

minimize the amount of controls should be established to to. These con- Administrative related area may be exposed combustibles that a safety to govern:

trols should be established combustibles, limitation on the use of a. the handling of and hazards such as flammable gases and and explosive exchange flammable filters, dry unused ion liquids, HEPA and charcoal supplies in safety related areas, resins or other combustible safety related to assure that these items are not stored in and areas.

and modifications the transient fire loads during maintenance and plastic b. flammable liquids, wood such as combustible and combustible mater- spilled oil, oil drums, and other systems or equip- products, safety related ials in buildings containingrequire an in-plant review of pro- ment. This control shouldidentify potential transient fire posed work activities to member designated the responsibility loads. The onsite staff for potential transient fire for reviewing work activities fire protection required additional loads should specify the in the work activity procedure.

to transient fire load causes the total fire load and When the systems of existing suppression exceed the capabilities suppression equipment should additional portable equipment, be brought into the area.

rags, oil spills, or the removal of all waste, debris, scrap, in the c. from the work activity, other combustibles resulting of the activity, or at the end of area following completion is sooner.

each work shift, whichever for accumulation of combustibles.

d. periodic inspection that it wood used in safety related areas to assure e. all is treated with flame retardant.

Attachment No. 4 CONTROL OF IGNITION SOURCES

1.0 Administrative Controls Administrative controls should be instituted to protect safety- related equipment.from fire damage or loss resulting from work involving ignition sources, such as welding, cutting, grinding, or open flame work; administrative controls should prohibit the use of open flame or combustion smoke for leak testing and controls should prohibit smoking and other ignition sources in certain areas.

2.0 Control of Weldina, Cutting, Grinding, and Open Flame Work a. Al' cutting, welding, grinding or open-flame work should oe authorized by the responsible foreman or supervisor through a work pernmiL. The responsible foreman or supervisor should have received a basic industrial fire fighting and fire prevention course covering anticipated fires, such as elec- trical fires, fires in cables and cable trays, hydrogen fires, hydrocarbon fires, solvent fires, waste/debris fires, and re- cord file fires.

b. Before issuing the permit, the responsible foreman or super- visor should physically survey the area where the work is to be performed and establish that the following precautions have been accomplished:

(1) All moveable combustible material below and within a 35 foot radius of the cutting, welding, grinding, or open flame work has been removed. (See NFPA 518)

(2) All immovable combustible material below and within a 35 foot radius has been thoroughly protected by asbestos curtains, metal guards, or flameproof covers, and fire extinguishers, hose, or other firefighting equipment are provided at the work site. (See NFPA 518)

(3) A fire watch trained and equipped to prevent and combat fires is present throughout any operations in which there is potential for fire Jtat mignt mfiff ge safety.

related equipment. A ire watcn s ou be proided where cutting, welding, grinding or open flame is performed above or within a radius of 35 feet of any open cables, flammable liquids, scaffold boards, paper, rags, or other objects on the same elevation of the work or if combustible materials are below the work area where openings exist. A fire watch should be provided for all

"-I

2 cutting, welding, grinding, and open flame work in the Control Room, Cable Spreading Room, Diesel Generator Rooms, and other safety related areas that contain sig- nificant amount of cable or flammable liquids. (See NFPA 51B)

The fire watch sould remain on the work site while work is performed and remain in the area for at least 30 min- utes after the work is completed to check for smoldering fires.

(4) All equipment to be used is in a safe, working condition.

Oxyacetylene equipment is checked for leaks before being moved to the work area.

c. The signature concurrence of a member of the plant's management or a quality control inspector certified to make this concurrence should be obtained whenever the supervisor or foreman determines that a fire watch is not required.

3.0 Leak Testing Administrative procedures should be established to prohibit the use of open flame or combustion smoke for leak testing. Work orders for leak testing should require the concurrence of the shift engineer to verify that the leak test method is acceptable and would not present a potential ignition source.

4.0 Smoking and Ignition Source Restriction Smoking should be prohibited in safety related areas, except where

"smoking permitted" areas have been specifically designated by a responsible member of plant management and in areas containing flammable or potentially explosive materials or atmospheres that present a hazard to safety related equipment. These areas should be identi- fied with "No Smoking" signs.

5 Attachment No.

.

FIRE FIGHTING PROCEDURES

such items as should be established to cover coordination of fire fighting procedures and of a fire, fire emergency procedures, notification activities with Of fire fighting procedureidentify_

ing p fire, such the to be taken by individual discovering extinguish fire, a. Actions control room, attempt to of as, notification fire suppression systems.

and actuation of local the need by the control room operator and of taken receipt b. Actions to beassistance upon report of a fire oras: announcing for brigade such room annunciator panel, and alarm on control over PA system, sounding fire alarms of location of fire leader supervisor and the fire brigade notifying the shift location of the fire.

the type, size, and by by the fire brigade after notification location to c. Actions to be taken of a fire, including:

the control room operator leader; and responsi- given by fire brigade fighting assemble; directions members such as selection of fire bilities of brigade selection of transportation to fire location, systems operating equipment and use of fire suppression for fighting protective equipment, strategies use of preplanned instructions, and areas.

fires in specific in all safety- established for fighting firesto safety-related d. The strategies and areas presenting a hazard should be related areas the following subjects equipment. As a minimum covered:

plant zone covered of combustibles in each

(1) Identification fire fighting procedures.

by the specific the fires suited for controlling

(2) Fire extinguishants best in that zone and with the combustible loadings associated of these extinguishants.

the nearest location a fire in direction from which to attack access

(3) Most favorable view of the ventilation direction, to be each area, in most likely doors which are hallways, stairs andbest station or elevation for fighting fire-free, and the shall designate identification system and system the fire. A specific doors, fire equipment in the fire all hallways, stairs, and other items described control locations, be used This identification should fighting procedures.

2 plant items should in the procedures and the corresponding be recognized in be prominently marked so that they can that involve dim light. All access and egress routes identified in the locked doors should be specifically and methods procedure with the appropriate precautions for access specified.

should be managed to

(4) Designation of plant systems that a local fire; location reduce the damage potential during management (e.g.,

of local and remote-controls for such the zone covered systems in any hydraulic or electrical that could by the specific fire fighting procedure of overpres- increase the hazards in the area because surization or electrical hazards).

system components

(5) Designation of vital heat-sensitive a local fire.

that should be kept cool while fighting which are particularly hazardous Critical equipment to receive combustible sources should be designated cooling.

and the assignment

(6) Organization of fire fighting brigades title so that all fire of special duties according to job complete shift per- fighting functions are covered by any include command sonnel complement. These duties should applying the control of the brigade, fire hose laying, support supplies to extinguishant to the fire, advancing control room, the fire scene, communication with the coordination with outside fire departments.

toxic hazards in fire

(7) Identification radiological and zones.

assures desired plant

(8) Ventilation system operation that flow is pressure distribution when the ventilation clearing operations.

modified for fire containment or smoke and shift engineer

(9) Operations requiring control room coordination or authorization.

and general plant per-

(10) Instructions for plant operators sonnel during fire.

strategies should be tested by e. The validity of the preplanning check the logic of the appropriate full-dress drills to personnel under- strategy, the adequacy of the equipment, problems.

standing, and to uncover unforeseen

I

and Superintendent and his staff, f. Actions to be taken by Plant a fire.

notification of Security Guards after activities to be taken that will coordinate fire fighting of g. Actions including: identification in with offsite fire departments, assessing situation and calling individual responsible for identification assistance when needed;

outside fire department fire fighting activities when of individual who will direct assistance; provisions for aided by offsite fire fighting organizations in fire brigade including offsite fire fighting and provisions for training year;

drills at least once per in basic radiation principles, department personnel in a offsite fire and precautions to be taken typical radiation hazards, The pro- involving radioactive materials in the plant.

fire the offsite fire department's cedures should also describe response time by the offsite fire resources and estimated to the station.

department to provide assistance

Attachment No. 6 QUALITY ASSURANCE

The quality assurance (QA) program should assure that the requirements for design, procurement, installation, testing, and administrative controls for the fire protection program for safety related areas approved by NRC are satisfied. The Quality Assurance provisions for fire protection should apply to activities performed after the effective date of the adoption of said provisions. The QA program should be under the management control of the QA organization. This control consists of

(1) formulating and/or verifying that the fire protection QA program incorporates suitable requirements and is acceptable to the management responsible for fire protection and (2) verifying the effectiveness of the QA program for fire protection through review, surveillance, arnd audits. Performance of other QA program functions for meeting the fire protection program requirements may be performed by personnel outside of the QA organization. The QA program for fire protection should be part of the overall plant QA program. These QA criteria apply to those items within the scope of the fire protection program, such as fire protection systems, emergency lighting, communication and emergency breathing apparatus as well as the fire protection requirements of applicable safety related equipment.

Applicants/licensees can meet the fire protection quality assurance (QA)

program criteria of Appendix A to BTP 9.5-1 or Regulatdry Guide 1.120

by either:

1) implementing those fire protection QA criteria as part of their QA

program under 10 CFR Part 50 Appendix B, where such a commitment is made, it is not necessary to submit a detailed description of the fire protection QA program or its implementation for NRC review; or

2) providing for NRC review a description of the fire protection QA

program and the measures for implementing the program. Supplemental guidance is provided below on acceptable measures for implementing each of the fire protection QA program criteria of Appendix A to BTP 9.5-1 or Regulatory Guide 1.120.

1.0 Design Control and Procurement Document Control - Measures should be established to assure that the applicable guidelines of the Regulatory Guide 1.120 or approved NRC alternatives are included in design and procurement documents and that deviations therefrom are controlled. These measures should assure that:

a. Design and procurement document changes, including field changes and design deviations are subject to the same level of controls, reviews, and approvals that were applicable to the original document.

2 b. Quality standards are specified in the design documents such as appropriate fire-protection codes and standards, and deviations and changes from these quality standards are controlled.

c. New designs and plant modifications, including fire protection systems, are reviewed by qualified personnel to assure inclusion of appropriate fire protection requirements. These reviews should include items such as:

(1) Design reviews to verify adequacy of wiring isolation and cable separation criteria.

(2) Design reviews to verify appropriate requirements for room isolation (sealing penetrations, floors, and other fire barriers)..

d. A review and concurrence of the adequacy of fire protection requirements and quality requirements stated in procurement documents are performed and documented by qualified personnel.

This review should determine that fire protection requirements and quality requirements are correctly stated, inspectable and controllable; there are adequate acceptance and rejection criteria; and-the procurement document has been prepared, re- viewed, ,nd approved in accordance with QA program requirements.

2.0 Instructions, Procedures, and Drawing - Inspections, tests, admin- istrative controls, fire drills, and training that govern the fire protection program should be prescribed by documented instructions, procedures or drawings and should be accomplished in accordance with these documents. The following provisions should be included.

a. Indoctrination and training programs for fire prevention and fire fighting are implemented in accordance with documented procedures.

b. Activities such as design, installation, inspection, test, maintenance, and modification of fire protection systems are prescribed and accomplished in accordance with documented in- structions, procedures, and drawings.

c. Instructions and procedures for design installation, inspec- tion, test, maintenance, modification and administrative controls are reviewed to assure that proper inclusion of fire protection requirements, such as precautions, control of ignition sources and combustibles, provisions for backup fire protection of the activity requires disabling a fire protection system, and re- striction on material substitution unless specifically permitted I

by design and confirmed by design review.

~i VF

3 seals and fire d. The installation or application of penetration personnel using retardant coatings is performed by trained approved procedures.

and Services - Measures

3.0 Control of Purchased Material, Equipment, material, equipment shall be established to assure that purchased These measures and services conform to the procurement documents.

should include:

evaluation and selection, a. Provisions, as appropriate, for source by the contractor, objective evidence of quality furnished inspections at suppliers, or receiving inspections.

a minimum, for those items b. Source or receiving inspection, as whose quality cannot be verified after installation.

of activities

4.0 Inspection - A program for independent inspectionand executed by, or affecting fire protection should be establishedto verify conformance for, the organization performing the activitytest procedures for s.o documented installation drawings and should include:

accomplishing activities. This program and modification of a. Inspections of (1) installation, maintenancelighting and communica- fire protection systems; and (2) emergency design and installation tion equipment to assure conformance to requirements.

retardant coating b. Inspection of penetration seals and fire satisfactorily completed.

installations to verify the activity is with design c. Inspections of cable routing to verify conformance requirements.

requirements for room d. Inspections to verify that appropriate and other fire barriers)

isolation (sealing penetrations, floors, are accomplished during construction.

are independent from e. Measures to assure that inspection personnel being inspected and are the individuals performing the activity requirements for fire knowledgeable in the design and installation protection.

check lists which provide f. Inspection procedures, instructions, and for the following:

activities to be

(1) Identification of characteristics and inspected responsible for

(2) Identification of the individuals or groups performing the inspection operation

(3) Acceptance and rejection criteria

4 the method of inspection

(4) A description of a manu- of completing and verifying

(5) Recording evidence test operation facturing, inspection or results of Recording inspector or data recorder and the

(6)

the inspection operation emergency breathing inspections of fire protection systems, communication equip- g. Periodic emergency lighting, and and auxiliary equipment, condition of these items.

ment to assure the acceptable degradation such as fire Periodic inspection of materials subject toto assure these items have i coatings stops, seals, and fire retardant damaged.

not deteriorated or been established and and Test Control - A test program should be and verified by

5.0 Test testing is performed implemented to ensure that with design and and audit to demonstrate conformance be performed in inspectioa The tests should system readiness requirements.procedures; test results should be test accordance with written acted on. The test program should include properly evaluated and the following: -

repair Testing - Following construction, modification, that demonstrate a. Installation testing is performed to or replacement, sufficientemergency lighting and communication equip- fire protection systems, in service and that design criteria ment will perform satisfactorily incorporate for installation tests are met. Written test procedureslimits contained in applicable the requirements and acceptance design documents.

for periodic testing The schedules and methods b. Periodic testing - Fire protection equipment, emergency documented. to are developed and equipment are tested periodically to lighting, and communication and continue will properly function assure that the equipment meet the design criteria.

of fire for QA/QC to verify testing are effectively c. Programs are established verify that test personnel protection systems and to trained.

are documented, evaluated, and their acceptability results gro4p.

d. Test responsible individual or determined by a qualified should be established Operating Status - Measureshave satisfactorily

6.0 Inspection, Test, and of items that to provide for the identificationinspections. These measures should include passed required tests and provisions for:

temporary of tags, labels, or similar a. Identification by means of required inspections and markings to indicate completion tests, and operating status.

5 to control items Nonconforming Items - Measures should be established prevent inadvertent

7.0 requirements to that do not conform to specified should include provisions to use of installation. These measures assure that:

or malfunctioning fire protection a. Nonconforming, inoperative, and communication equipment are systems, emergency lighting, labelled.

appropriately tagged or review dis- The identification, documentation, segregation, of b. to the affected organization position, and notificationparts, components, or services are nonconforming materials, procedurally controlled.

describes the identifies the nonconforming item, c. Documentation of the nonconforming item nonconformance and the disposition of the disposition.

and includes signature approval or are established identifying those individuals the d. Provisions and authority for groups delegated the responsibility of nonconforming items.

disposition and approval that con- Action - Measures shall be established to ensure

8.0 Corrective malfunctions, protection such as failures, ditions adverse to fire defective components, uncontrolled combus- deficiencies, deviations, reported are promptly identified, tible material and nonconformances should assure:

and corrected. These measures adverse for evaluation of conditionsmal- a. Procedures are established as nonconformance, failures, to fire protection (such deviations, and defective material functions, deficiencies, the necessary corrective action.

and equipment) to determine adverse or repetitive conditions b. In the case of significant fire incidents, the cause of to fire protection, including corrective and analyzed, and prompt the conditions is determined The cause of the are taken to preclude recurrence. are promptly reported actions action taken condition and the corrective for review and assessment.

to cognizant leveis of management to furnish be prepared and maintained

9.0 Records - Records should enumerated above are being met for evidence that the criteria The following affecting the fire protection program.

activities provisions should be included:

demonstrate and retrievable and should should a. Records are identifiable requirements. The records conformance to fire protection

6 include results of inspections, tests, reviews, and audits; non- conformance and corrective action reports; construction, maintenance and modification records; and certified manufacturers' data.

b. Record retention requirements are established.

lo.0Audits - Audits should be conducted and documented to verify compliance with the fire protection program, including design and procurement documents, instructions, procedures, and drawings, and inspection and test activities. The following provisions should be included:

a. Audits are periodically performed to verify compliance with the administrative controls and implementation of quality assurance criteria including design and procurement, instructions, procedures and drawings and inspection and test activities. These audits are performed by QA personnel in accordance with preestablished written procedures or check lists and conducted by trained personnel not having direct responsibilities in the areas being audited.

b. Audit results are documented and then reviewed with management having responsibility in the area audited.

c. Followup action is taken by responsible management to correct the deficiencies revealed by the audit.

d. Audits are annually performed to provide an overall assessment of conformance to fire protection requirements.