NRC Generic Letter 1978-23

NRC Generic Letter 1978-023: Manpower Requirements for Operating Reactors

ML031280307
Person / Time
Issue date:	06/08/1978
From:	Stello V Office of Nuclear Reactor Regulation
To:
References
NUDOCS 8101100554, GL-78-023
Download: ML031280307 (10)

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DISTRIBUTION:

ODetRet JUN 8 1978 , NRC PDR

Local PDR

ORB#2 RDG 7 DLZiemann -

Docket t 50-5 HSmith SNowicki TVWambach Consumers Power Company OELD I- - 2gY- 2,3 ATTP: Nr. David Bixel OI&E (3)

Nuclear Licensing Administrator DEisenhut

212 Hest Michigan Avenue YStello Jackson, Mich1gan 49201 TBAbernathy JRBuchanan Gentlemen: ACRS (16)

RE: MAPTPOWER REQUIREMIENTS FOR OPERATING REACTORS

We are enclosing a docuwent entitled, llanpower Requirements for Operating Reactors.6 We are using the bases given in this document for allowing the sharing of duties to neet minimun staffing require- rents for fire brigades at nuclear power plants. This is being provided for your guidance in meeting NfC requirements in this area.

By letter dated December 15, 1977, you objected to a require- ment for a rdninimum fire brigade size of 5 being incorporated in the Technical Specifications for the 8ig Rock Point Plant. lVe request that you review the enclosed guidance in regard to the use of personnel on the operating staff and security force in ianning the fire brigade and inform us by letter within twenty days whether you continue to object to our position on a-ininum fire briaade size.

Sincerely, IS

Victor Stello, Jr., Director Division of Operating Reactors Office of Nuclear Peactor Regulation Enclosure:

fanpower Requirenents for Operating Reactors cc w/encl:

See next page

8 1 0 1 10 0 5 5 4 > pr NRC FORM 318 (9-76) NRCM 0240

1976 - O2ZS624

Consumers Power Company - 2 - June 8, 1978 cc Mr. Paul A. Perry, Secretary Consumers Power Company

212 West Michigan Avenue Jackson, Michigan 49201 Judd L. Bacon, Esquire Consumers Power Company

212 West Michigan Avenue Jackson, Michigan 49201 Hunton & Williams George C. Freeman, Jr., Esquire P. 0. Box 1535 Richmond, Virginia 23212 Peter W. Steketee, Esquire

505 Peoples Building Grand Rapids, Michigan 49503 Charlevoix Public Library

107 Clinton Street Charlevoix, Michigan 49720

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MANPOWER REQUIREMENTS FOR OPERATING REACTORS

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 Requirements S-

1. Fire Brigade: The staff has concl¶ded 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.

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.

The NRC staff has given consideration to the appropriateness of per- 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 brigade staffing could generally be provided through operations and security personnel, and (2)the requirements for operators and the security force should remain uncompromised. Until a site specific review is completed, the following indicates the interim distribution and justification for these dual assignments, and therefore our interim minimum requirements for a typical presently operating commercial 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-term 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 background in plant operations and overall familiarity with the plant. In this regard, the shift supervisor should not be the fire brigade leader e 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 procedures will be used in deploying the security organization to assure that an 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 such as a fire. Further examination of this issue leads to two 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?

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

II.

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 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- man rule is required. These measures to contain the insider are presently being implemented and will provide assurance that people 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 recommended to the Commission 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 force 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 maintained for external diversionary fires.

The second potential rationale concerns whether a serious, 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 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 of these two unlikely events would be sufficiently small to not

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-4- 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 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 afire, 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 force should be actively evaluating the possibility of any security threat to the plant and taking any actions which are necessary to 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 considered. -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 that it would be reasonable to allow a limited amount of sharing of plant personnel in satisfying the requirements of plant operation, security, and fire protection. An acceptable 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 would be governed by the exigencies of the situation. Of course, all personnel assigned to the fire brigade would have to fulfill all applicable 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 plans. Minimum protection levels -n either area could preclude the sharing of manpower.

Attachment A -

Staff Position minimum Fire Brigade Shift Size I . lODUCTI O.'

an onsite fire brigade Nuclear power plants depend on the response of plant safe shutdown for defense against the effects of fire on brigade are the capabilities. In some areas, actions by the fire that are protected only weans of fire suppression. In other areas, systems, by correctly desin.ed auto"atic detection and suppression (1) fires too mantial fire fighting efforts are used to extinguish:

developed fires if the small to actuate the automatic system; (2) well that are not completely auton"1tic system fails to function; and (3)anfires adequate fire brigade is controlled by the automatic system. Thus, requirements which protect essential to fulfill the defense in depth and-their related safe shutdown systems from the effects of fires combustion by-products.

DISCUSSION

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

1) plant pecmetry and size; systems;

2) quantity and -quality of detection arnd suppression

3) fire fighting strategies for postulated fires;

4) fire brigade training;

5) fire brigade equipment; and and local fire

6) fire brigade supplements by plant personnel department(s).

are in enclosed window- In all plants, the majority of postulated fires of the brigade less structures. In such areas, the working environment enclosure, will require created by the heat and smoke buildup within thesmoke ventilation equipment, the use of self-contained breathing apparatus, and a personnel replacement capability.

i.e., command brigade Certain functions must be performed for all fires, ventilation control, actions. inform plant management, fire suppression,injuries. Until a site provide extra equipment, and account for possible minimum fire brigade size.

specific review can be completed, an interim brigade size should provide of five persons has been established. This with those postulated a minimum working number of personnel to deal nuclear power station.

fires in a typical presently operating commercial

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- 2 If the brigade is composed of a smaller number ofneeded personnel, the fire new equipment is or a person is

4attack may be stopped whenever fire service, the injured or fatigued. We note that in tfie career for an initial Minimum engine company manning considered to be effective officer and four team members.

attack oni-a fire is also five, including one that brigade training It is assumed for the purposes of this position of trained and equipment is adequate and that a backup capability call back or from Individuals exist whether through plant personnel the local fire department.

PQSITIOU

justified by an analysis

1. The minimum fire brigade shift size should be plant, after of the plant specific factors stated above for the modifications are cc;aplete.

shall be five

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

tactics trainina.

One Su!)ervisor - This individual must have fire F-vFili assume all command responsibilities for fighting the fire.

not have During plant ermeraencies, the brigade supervisor should attention his full other responsibilities that would detract from not be actively being devoted to the fire. This supervisor should should be

.engagged in the fighting of the fire. His total functionthe upper keep to survey the fire area, command the brigade, and levels of plant management informed.

a window- Two Hose Men - A 1.5 inch fire hose being handled within two The less enclo1sure would require two trained individuals. active hose line team members are required to physically handle the of the and to protect each other while in the adverse environment fire.

be Two Additional Them Members - One of these individuals would fire fighting re-quirc to supply FIlled air cylinders to the ventilation members of the brigade and the second to establish.smoke would and aid in filling the air cylinder. These two individuals also act as the first backup to the engaged team.

4^'. - c. wAT : ,j l A . TA

4. a. Assignments of personnel meteting AMS1 N18.1-1971 Cualificeiions. Section 4.3.1 or Section 4..1, should be made to onsite shift operatino CftwS in numbers not less than the following:

For a station having one licensed unit, each shift crew should have at least three persons at all tires, plus two additional persons when the!unit is operating.

For a multi-unit station, each shift crew should have at least three persons per licensed unit at all times, plus one additional person per operating unit.

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

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

(2) For any station with more than one reactor containing fuel, (1)the number of licensed senior operators onsite at all times should not be less than the number of control rooms from which the fueled units are monitored, and

(2) the number of licensed senior operators should not be less than the number of reactors operating.

(3) For each reactor containing fuel. there should be at least one licensed operator in the control rootr at all times. Shift crem compositions should be specified such that this condition can be satisfied independently of licensed senior operators assigned to shift crews to meet the criteria of

(1)and (2)above.

(4) For each control room from which one or more reactors are in operation, an additional operator should be onsite and available to serve as relief operator for that control room. Shift crew compositions should be specified such that this condition can be satisfied independently of (1), (2). and

(3), and for each such control room.

c. Radiation protectior cualif'cations of at least one person on eact operating shift should be as follows:

The management of each station having one or more units containing fuel should either, (1)qualify and designate at least one member of eacn shift operating crew to implement radiation protection procedures, including routine or special radiation surveys using portatle radiation detectors, use of protec- tive barriers and signs, use of protective clothing and breathing apparatus.

performance of contamination surveys, checks on radiation monitors, and limits of exposure rates and accumulated dose. or (2)assign a health physics technician to each shift, Such assignment to be in addition to those assignee to shift operating crews in accgrdance with (a)and (b)above.

111. REVIEW PRO-_URES

Selection and t ,.,hasis of various aspects of the areas covered by this review plan will be made by the revieaer on each case. The Judgment on the areas to be given attentior during

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