Additional Services
See below for additional services Tri-En Corporation can provide.
Penetration Seal Programs
Fire barriers are an important element in the defense-in-depth philosophy for preventing the spread of fires. A critical function of facility's Fire Protection Program is in maintaining the integrity of fire barriers. Because penetration seals are an integral part of a fire barrier, the proper design, selection, and/or evaluating their performance capabilities is crucial in demonstrating adequacy of the barrier.
Tri-En's engineers have extensive experience in all facets of a Penetration Seal Program. We have utilized our expertise in this field to help numerous clients in evaluating and establishing adequacy of their fire barriers and Penetration Seal Programs.
Quality Assurance Audits
The purpose of Quality Assurance audits is to have an independent fire protection consultant assess a plant’s Fire Protection Program implementation to verify that a level of fire safety continues to be provided in accordance with the licensee's commitments.
For nuclear facilities, the audit scope encompasses verifying that Nuclear Regulatory Commission (NRC) requirements, station commitments and licensing conditions applicable to fire protection are being met.
Typically, the scope of these audits include the following activities:
- A walk-through inspection of the plant to verify that fire protection is properly maintained and no combustible loading problems exist.
- Verification that a selected sample of fire protection related surveillance tests has been satisfactorily completed at the required frequencies, and verification that any discrepant conditions that were identified by these tests received the proper follow-up attention.
- Verification that a selected sample of fire brigade members has received the required annual training, physical examination and respirator qualification test.
- Verification that the correct number and type of fire brigade drills and practice sessions were performed during the year.
- Verification that the required personnel participated in these activities.
- Verification that a selected sample of licensing basis conditions, BTP 9.5.1. Safety Evaluation Report and Appendix R commitments continue to be satisfactorily fulfilled.
- Review fire fighting procedures and strategies.
Tri-En has provided consultant support and performed audits for QA personnel from various facilities. These efforts have been beneficial to our clients overall results when the NRC conducted their reviews.
Configuration Control Management Programs
Configuration Control Management Programs provide for proper documentation of plant configurations and procedures used for operating a facility and maintenance of an effective Fire Protection Program. Such documentation is needed to demonstrate that the owner of a plant fully understands the nuances involved with the Fire Protection Program, and that the operation will not be adversely affected by changes. Configuration control management involves maintaining processes/procedures related to fire prevention, fire protection systems, safe shutdown systems, and licensing basis commitments.
Tri-En has performed reviews of the effectiveness of configuration controls for the Fire Protection Programs of numerous facilities. Our engineers will evaluate the existing controls being implemented in a facility and compare it with the Fire Protection Program requirements and commitments. The results will determine the effectiveness of the procedural controls being utilized to maintain your Fire Protection Program. Examples of configuration controls are related to maintaining Fire Protection Program goals when changes to organization, design, licensing basis, operating procedures, and plant conditions occur. As such, our perspectives in assessing a particular facility provide the experience and knowledge gained throughout the industry.
Loss Prevention Inspections
Property Loss Prevention Inspections provide an internal perspective on how well a facility is prepared for perils such as fire, earthquake, floods, or explosions. The loss prevention inspections utilize the insurance industry's High Probability Risk (HPR) techniques to identify potential risks to life safety and property, as well as adverse impacts to continuity of operations.
Tri-En's can perform loss prevention inspections for all business units of a utility, including;
- Power plants (nuclear, fossil, natural gas, hydro)
- Electric transmission and distribution substations
- Gas compressor stations
- Computer centers, and
- Field offices
Risk Management Programs
The goal of the Risk Management Program is to prevent accidental releases of certain substances that can cause serious serious harm to the public and the environment, and to mitigate the consequences of releases that do occur.
A facility's Risk Management Plan is an element of the Risk Management Program, and addresses the potential consequences of an accidental release of various hazardous materials stored in specified quantities. While most facilities do not use or store quantities in excess of amounts that would trigger the need for a Risk Management Plan, the owner of a facility must ensure they are not subject to these requirements.
EPA Rule
Under the 1990 Amendments to the Clean Air Act, the Environmental Protection Agency (EPA) issued a rule to require facilities that manufacture, use, or store any of the toxic and flammable substances listed in 40 CFR 68.130 above the specified threshold quantities develop and implement a Risk Management Program.
Part 68 to CFR 40 requires that covered facilities develop and implement a Risk Management Program and maintain documentation of the program at the site. This program is to be summarized and submitted to the EPA in the facility Risk Management Plan (RMP) which includes an analysis of the potential offsite consequences of an accidental release, a five-year accident history, a release prevention program, and an emergency response program.
The RMP is designed to;
- protect the public and the environment beyond the fence-line of a property,
- prevent accidental chemical releases, and
- minimize the consequences of off-site incidents.
There are three basic elements to a facility RMP;
- Hazard Assessment: This element identifies the chemical hazards and the potential effects of releases, including the worst case release scenario.
- Accident Prevention Program: this element outlines programs and processes to prevent accidents.
- Emergency Response Program: This element details plans to mitigate the effects of accidental releases.
The amount of information that must be submitted depends on the program category applicable to your facility. Program 1 has the fewest requirements, with Program 2 and Program 3 having increasingly more restrictive requirements, respectively.
What should you do?
- Determine if your facility is subject to the RMP rules (i.e., do you have more than the threshold quantity of a regulated substance on-site?)
- If so, determine what level of reporting requirements is applicable (i.e., can you satisfy your reporting requirements under Program 1, or are you subject to the requirements of Program 2 or 3?)
- Develop a strategy for implementing the Risk Management Program (i.e., can you make facility changes removed the facility from the RMP reporting requirements)
How can Tri-En help?
Tri-En can assist in determining if a facility is subject to the RMP, assist in development of the facility RMP, and/or identify potential changes that would eliminate the need for a facility to submit an RMP
Licencing Support
Maintenance of a facilities license bases is an important part to ensuring that a plant is operating in a manner that has been accepted by the NRC. The plants Safety Analysis Report (SAR) and references describe the facility and the method at which it will operate. It also describes the ability for a facility to mitigate the consequences of various design basis accidents.
Tri-En engineers have extensive licensing background and knowledge of SAR and regulatory requirements. Our engineers have assisted clients in verifying the contents of their SAR/FSAR against the actual plant conditions and determined acceptable resolutions to differences identified. The following licensing support have been provided:
- FSAR Reviews and Updates
- Assisted in generating Licensee Event Reports and License Amendment Requests
- Generation of Exemption Requests
- Operability Assessments
- License Basis Re-Verification
- Safety Evaluations
Fire Protection Program Training
A plant's Fire Protection Program can remain effective if the personnel responsible for maintenance of the program are knowledgeable in every aspect of the program. Fire Protection Program requirements have existed since the plant's construction. Because the amount of the information included in the program documents, and the turnover of plant personnel, most knowledge of the Fire Protection Program can be lost.
Tri-En engineers have generated and maintained Fire Protection Programs and are very familiar with both the requirements and the level of documentation generated. Tri-En engineers can review a plant's Fire Protection Program (including design and licensing basis requirements), and provide training courses to plant personnel to educate them on the facility's program. Plant personnel have included upper management level to entry-level fire protection engineers, as well as cross-train other related disciplines such as licensing, operations, design engineers and QA personnel.