NRC Generic Letter 1978-23
| 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) | |
--JUN 8 1978 ,Docket t 50-5Consumers Power CompanyATTP: Nr. David BixelNuclear Licensing Administrator212 Hest Michigan AvenueJackson, Mich1gan 49201Gentlemen:DISTRIBUTION:ODetRetNRC PDRLocal PDRORB#2 RDG 7DLZiemann -HSmithSNowickiTVWambachOELDOI&E (3)DEisenhutYStelloTBAbernathyJRBuchananACRS (16)I- -2gY- 2,3RE: MAPTPOWER REQUIREMIENTS FOR OPERATING REACTORSWe are enclosing a docuwent entitled, llanpower Requirements forOperating Reactors.6 We are using the bases given in this documentfor allowing the sharing of duties to neet minimun staffing require-rents for fire brigades at nuclear power plants. This is beingprovided for your guidance in meeting NfC requirements in thisarea.By letter dated December 15, 1977, you objected to a require-ment for a rdninimum fire brigade size of 5 being incorporated inthe Technical Specifications for the 8ig Rock Point Plant. lVerequest that you review the enclosed guidance in regard to the use ofpersonnel on the operating staff and security force in ianning thefire brigade and inform us by letter within twenty days whether youcontinue to object to our position on a-ininum fire briaade size.Sincerely,I SVictor Stello, Jr., DirectorDivision of Operating ReactorsOffice of Nuclear Peactor RegulationEnclosure:fanpower Requirenents forOperating Reactorscc w/encl:See next page8 1 0 1 1 0 0 5 5 4 > prNRC FORM 318 (9-76) NRCM 02401976 -O2ZS624 Consumers Power Company -2 -June 8, 1978ccMr. Paul A. Perry, SecretaryConsumers Power Company212 West Michigan AvenueJackson, Michigan 49201Judd L. Bacon, EsquireConsumers Power Company212 West Michigan AvenueJackson, Michigan 49201Hunton & WilliamsGeorge C. Freeman, Jr., EsquireP. 0. Box 1535Richmond, Virginia 23212Peter W. Steketee, Esquire505 Peoples BuildingGrand Rapids, Michigan 49503Charlevoix Public Library107 Clinton StreetCharlevoix, Michigan 49720
v X E -- ---"-MANPOWER REQUIREMENTS FOR OPERATING REACTORSThe NRC has established requirements for personnel at operatingreactors for purposes of plant operation, industrial security, andfire fighting. The following discussion considers the extent towhich plant personnel assigned to either plant operation or securitymay also be temporarily allowed to man a fire brigade in the eventof a fire for a single unit facility and sets forth an acceptablesharing scheme for operating reactors.S- Summary of Manpower Requirements1. Fire Brigade: The staff has concl¶ded that the minimum sizeof the fire brigade shift should be five persons unless aspecific site evaluation has been completed and some othernumber Justified. The five-man team would consist of oneleader and four fire fighters and would be expected toprovide defense against the fire for an initial 30-minuteperiod. See Attachment A for the basis for the need for afive-man fire brigade.2. Plant Operation: Standard Review Plan Section 13.1.2 requiresthat for a station having one licensed unit, each shift crewshould have at least three persons at all times, plus twoadditional persons when the unit is operating. For ease ofreference, Attachment B contains a copy of this SRP.3. Plant Security: The requirements for a guard force are outlinedin 10 CFR Part 73.55. In the course of the staff's review ofproposed security plans, a required minimum security responseforce will be established for each specific site. In additionto the response team, two additional members of the securityforce will be required to continuously man the Central AlarmStation (CAS) and Secondary Alarm Station (SAS). It is expectedthat many facilities will have a security organization withgreater numbers of personnel than the minimum number assumedfor 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 ofplant operation, security and fire protection and has concluded that,(1) subject to certain site and-plant specific conditions, the firebrigade staffing could generally be provided through operations andsecurity personnel, and (2) the requirements for operators and thesecurity force should remain uncompromised. Until a site specificreview is completed, the following indicates the interim distributionand justification for these dual assignments, and therefore our interimminimum requirements for a typical presently operating commercialsingle unit facility. The staff believes that manpower for the firebrigade for multi-unit facilities is not now a problem because of thelarger numbers of people generally present at the sites. Situationswhich do pose problems will be reviewed on a case-by-case basis.
-2-1. Plant Operation: The staff has concluded that for most eventsat a single unit nuclear facility, a minimum of three operatorsshould be available to place the reactor In a safe condition.The two additional operators required to be available at thenuclear facility are generally required to be present to performroutine jobs which can be interrupted to accomodate unusualsituations that may arise. That is, there is the potential forthe remaining two members of the operating crew to assume othershort-term duties such as fire fighting. In light of the originalrationale for providing extra plant operators to cope with off-normal conditions, it appears justified to rely on these personnelfor this function. The staff recommends that one of the twooperators assigned to the fire brigade should be designated asleader of the fire brigade in view of his background in plantoperations and overall familiarity with the plant. In this regard,the shift supervisor should not be the fire brigade leader ebecause his presence is necessary elsewhere if fires occur incertain critical areas of the plant.2. Plant Security: In the event of a fire, a contingency plan andprocedures will be used in deploying the security organizationto assure that an appropriate level of physical protection ismaintained during the event. The staff has determined that itis possible in the planning for site response to a fire, to assigna maximum of three members of the security organization to serveon the fire brigade and still provide an acceptable level of physicalprotection. While certain security posts must be manned continuously(e.g., CAS, SAS), the personnel in other assignments, including theresponse force, could be temporarily (i.e., 30 minutes) assigned tothe fire brigade. In judging the merits of this allowance theunderlying question is whether the minimum security force strengthmust be maintained continuously in the event of a plant emergencysuch as a fire. Further examination of this issue leads to twopotential rationales for reaching an affirmative decision. First,could there be a causal connection between a fire and the securitythreat? Second, are there compelling policy reasons to postulatea simultaneous threat and fire?The first potential rationale would only be credible if, (1) theinsider (posed as part of the threat definition) was an activeparticipant in an assault and started a fire coincident with theattack on the plant or, (2) a diversionary fire was started by anattack force somewhere external to the plant Itself where noequipment required for safe shutdown is located. The role ofthe insider will be discussed first. While 73.55 assigns an activestatus to the insider, the rule also requires that measures beimplemented to contain his activities and thereby reduce his II.effectiveness. At present, these measures include backgroundchecks on plant employees, limited access to vital plant areas,badging systems and the two-man rule. Here, limited accessmeans that only designated employees are allowed in vital areasand that their entry is controlled by either conventional locksor 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 arepresently being implemented and will provide assurance that peopleof questionable reliability would not be able to gain employeestatus at a nuclear plant and should they become an employeewith unescorted access, significant restraints would-be inter-posed on the ability of such a person to carry out extensivedamage to plant vital areas. Recognizing that additionalsafeguards may still be appropriate, the staff has recommendedto the Commission that plant personnel also be required to obtainan NRC security clearance. The staff believes that the attendantbackground investigation associated with a clearance, in con-Junction with the other 73.55 measures, will provide a highdegree of assurance that plant personnel will not attempt totake an active sabotage role. If the clearance rule is adoptedthe staff believes some of the measures, such as the two-manrule, designed to contain the insider can be relaxed. Thus,there does not now appear to be a reasonably credible causativerelationship between a fire intentionally set by an insiderand the postulated external security threat. For the case ofdiversionary fires set external to the plant itself, adequatesecurity forces can still be maintained by allowing only partof the fire brigade to respond while both fire fighters and securityforce armed responders maintain a high degree of alertness fora possible real attack somewhere else on the plant.. Thus, theeffective number of armed responders required by 73.55 can bemaintained for external diversionary fires.The second potential rationale concerns whether a serious,spontaneous fire should be postulated coincident with an externalsecurity threat as a design basis. In evaluating such a require-ment it is useful to consider the likelihood of occurrence ofthis combination of events. While it. is difficult to quantifythe probability of the 73.55 threat, it is generally acceptedthat it is small, comparable probably to other design basis typeevents. The probability of a fire which is spontaneous andlocated in or in close proximity to a vital area of the plantand is serious enough to pose a significant safety concern isalso small. It would appear, therefore, that the random coincidenceof these two unlikely events would be sufficiently small to not U-4-require protection against their simultaneous occurrence. Inaddition, it should be noted that the short time period (30 minutes)for which several members of the security force would be dedicatedto the fire brigade would further reduce the likelihood of coincidence.As neither of the two potential rationales appear to preclude theuse of members of the security force in the event of a fire thestaff has concluded that the short assignment of security personnelfrom the armed response force or other available security personnelto the fire brigade under these conditions would be acceptable.To ensure a timely and effective response to afire, while stillpreserving a flexible security response, the staff believes thatthe fire brigade should operate in the following manner. In theevent of an internal fire, all five members of the fire brigadeshould be dispatched to the scene of the fire to assess the natureand seriousness of the fire. Simultaneously, the plant securityforce should be actively evaluating the possibility of any securitythreat to the plant and taking any actions which are necessary tocounter that threat. For external fires, a lesser number thanthe 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 plantoperations, security and fire protection would be made, allowinga balanced utilization of manpower resources until offsite assistancebecomes available. The manpower pool provided by the plant operationspersonnel and security force are adequate to respond to theoccurrence of a design basis fire or a security threat equivalentto the 73.55 performance requirements. It is also recognized thatother, more likely combinations of postulated fires and securitythreats of a lesser magnitude than the design basis, could beconsidered. -While the probabilities of these higher likelihoodevents may be sufficient to warrant protecting against them incombination, the manpower requirements required to cope with eachevent would be similarly reduced thereby allowing adequate coverageby plant personnel.ConclusionThe staff believes that it would be reasonable to allow a limitedamount of sharing of plant personnel in satisfying the requirementsof plant operation, security, and fire protection. An acceptablesharing scheme would entail reliance on two plant operators andthree members of the security organization to constitute the firebrigade. Since availability of the full fire brigade would only
.m l -c r-s -be required for fires with potential for serious damage, actualdistribution of plant personnel during a plant emergency would begoverned by the exigencies of the situation. Of course, all personnelassigned to the fire brigade would have to fulfill all applicabletraining requirements. It should also be recognized that thediversion of personnel to the fire brigade would be of short durationand that substantial additional offsite assistance would be forthcomingin accordance with the emergency and contingency plan developedfor each facility. In evaluating licensee proposals for manpowersharing due consideration will also have to be made of uniquefacility characteristics, such as terrain and plant lay-out, aswell as the overall strengths of the licensee's fire and securityplans. Minimum protection levels -n either area could precludethe sharing of manpower.
Attachment A -Staff Positionminimum Fire Brigade Shift SizeI .lODUCTI O.'Nuclear power plants depend on the response of an onsite fire brigadefor defense against the effects of fire on plant safe shutdowncapabilities. In some areas, actions by the fire brigade are theonly weans of fire suppression. In other areas, that are protectedby correctly desin.ed auto"atic detection and suppression systems,mantial fire fighting efforts are used to extinguish: (1) fires toosmall to actuate the automatic system; (2) well developed fires if theauton"1tic system fails to function; and (3) fires that are not completelycontrolled by the automatic system. Thus, an adequate fire brigade isessential to fulfill the defense in depth requirements which protectsafe shutdown systems from the effects of fires and-their relatedcombustion by-products.DISCUSSIONThere are a number of factors that should be considered in establishingthe minin:um fire brigade shift size. They include:1) plant pecmetry and size;2) quantity and -quality of detection arnd suppression systems;3) fire fighting strategies for postulated fires;4) fire brigade training;5) fire brigade equipment; and6) fire brigade supplements by plant personnel and local firedepartment(s).In all plants, the majority of postulated fires are in enclosed window-less structures. In such areas, the working environment of the brigadecreated by the heat and smoke buildup within the enclosure, will requirethe use of self-contained breathing apparatus, smoke ventilation equipment,and a personnel replacement capability.Certain functions must be performed for all fires, i.e., command brigadeactions. inform plant management, fire suppression, ventilation control,provide extra equipment, and account for possible injuries. Until a sitespecific review can be completed, an interim minimum fire brigade size.of five persons has been established. This brigade size should providea minimum working number of personnel to deal with those postulatedfires in a typical presently operating commercial nuclear power station.
I 1-2If the brigade is composed of a smaller number of personnel, the fire4attack may be stopped whenever new equipment is needed or a person isinjured or fatigued. We note that in tfie career fire service, theMinimum engine company manning considered to be effective for an initialattack oni-a fire is also five, including one officer and four team members.It is assumed for the purposes of this position that brigade trainingand equipment is adequate and that a backup capability of trainedIndividuals exist whether through plant personnel call back or fromthe local fire department.PQSITIOU1. The minimum fire brigade shift size should be justified by an analysisof the plant specific factors stated above for the plant, aftermodifications are cc;aplete.2. In the interim, the minimum fire brigade shift size shall be fivepersons. These persons shall be fully qualified to perform theirassigned responsibility, and shall include:One Su!)ervisor -This individual must have fire tactics trainina.F-vFili assume all command responsibilities for fighting the fire.During plant ermeraencies, the brigade supervisor should not haveother responsibilities that would detract from his full attentionbeing devoted to the fire. This supervisor should not be actively.engagged in the fighting of the fire. His total function should beto survey the fire area, command the brigade, and keep the upperlevels of plant management informed.Two Hose Men -A 1.5 inch fire hose being handled within a window-less enclo1sure would require two trained individuals. The twoteam members are required to physically handle the active hose lineand to protect each other while in the adverse environment of thefire.Two Additional Them Members -One of these individuals would bere-quirc to supply FIlled air cylinders to the fire fightingmembers of the brigade and the second to establish.smoke ventilationand aid in filling the air cylinder. These two individuals wouldalso act as the first backup to the engaged team.
4^'. A .-TA c. wAT : ,j l4. a. Assignments of personnel meteting AMS1 N18.1-1971 Cualificeiions. Section 4.3.1 orSection 4..1, should be made to onsite shift operatino CftwS in numbers not lessthan the following:For a station having one licensed unit, each shift crew should have at least threepersons 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 perlicensed unit at all times, plus one additional person per operating unit.b. Operator license qualifications of persons assigned to operating shift crewsshould be as follows:(1) A licensed senior operator who is also a member of the station supervisorystaff should be onsite at all times when at least one unit is loaded withfuel.(2) For any station with more than one reactor containing fuel, (1) the numberof licensed senior operators onsite at all times should not be less than thenumber of control rooms from which the fueled units are monitored, and(2) the number of licensed senior operators should not be less than thenumber of reactors operating.(3) For each reactor containing fuel. there should be at least one licensedoperator in the control rootr at all times. Shift crem compositions shouldbe specified such that this condition can be satisfied independently oflicensed 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, anadditional operator should be onsite and available to serve as reliefoperator for that control room. Shift crew compositions should be specifiedsuch 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 operatingshift should be as follows:The management of each station having one or more units containing fuel shouldeither, (1) qualify and designate at least one member of eacn shift operatingcrew to implement radiation protection procedures, including routine orspecial 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 limitsof exposure rates and accumulated dose. or (2) assign a health physics technicianto each shift, Such assignment to be in addition to those assignee to shiftoperating crews in accgrdance with (a) and (b) above.111. REVIEW PRO-_ URESSelection and t ,.,hasis of various aspects of the areas covered by this review plan will bemade by the revieaer on each case. The Judgment on the areas to be given attentior during131 .2-311/247 5