ML19282A636
| ML19282A636 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 02/27/1979 |
| From: | Stewart W FLORIDA POWER CORP. |
| To: | Reid R Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 7903050231 | |
| Download: ML19282A636 (17) | |
Text
C090
- 0 0
O O
C Dh h<*?
69
- 0 C'~~
O*
- 99C Florida Power
- w. e. srowaar. oin ecron POWER PRODUCTION C O R P O A A T IO N February 27, 1979 Mr. Robert E. Reid Chief, Operations Reactor Branch #4 Division of Operating Reactors U.S. Nuclear Regulatory Commission Washington, DC 20555
Subject:
Crystal River Unit 3 Docket No. 50-302 Ope rating License No. DPR-72
Dear Mr. Reid:
On January 9,1979, Florida Power Corporation submitted a schedule for our responses to the NRC's letters of November 14, 1978, November 21, 1978, and December 20, 1978. As indicated in the letter, responses to twelve (12) questions and requests were scheduled for February 27, 1979.
Enclosed you will find responses to the following: - Questions 3, 25, 29, 33, 37, 38, 57, 72 - SRPs 4, 38 November 21, 1978 letter - P-5, 72 Response to Question #2 is not completed as of this date. This response will be submitted as soon as it is completed.
Should you or members of your staff wish to discuss our responses to these NRC concerns, please contact this office.
Very truly yours, FLORIDA POWER CGRPORAT ON LeRdaad W.P. Stewart Q
Enclosure Taylor (FireProt)
D9 File: 3-0-3-a-3 General Office 3201 Tnirty-fourtn street south. P.O Box 14042, St. Petersburg. Florida 33733 813-866-5151
STATE OF FLORIDA COUNTY OF PINELLAS W.P. Stewart states that he is the Director, Power Production, of Florida Power Corporation; that he is authorized on the part of said company to sign and file with the Nuclear Regulatory Commis.cion the information attached hereto; and that all such statements made and matters set forth therein are true and correct to the best of his knowledge, information and belief.
1
\\
llCCN W.P. Stewart Subscribed and sworn to before me, a Notary Public in and for the State and County above named, this 27th day of February, 1979.
Y.t-st $lW n
(s c--
Notary Public Notary Public, State of Florida at Large, My Commission Expires: August 24, 1979 (Notary 2 D12)
QUESTION 3.
INSTRUMENT AIR SYSTEM Verify that the effects of a fire on the instrument air system will not cause a transient more severe than those already analyzed in the FSAR.
RESPONSE
Of the systems which have the potential for initiating a transient, the makeup system, the main system and the feed-water system contain air-operated valves and controls, in the main steam system, air operated valves bypass steam directly from the main stream leads to the condenser and to the atmosphere.
Opening of these valves would cause an increase in ste&n flow and thereby tend to reduce reactor coolant temperature.
Transients due to steam line breaks have been analyzed in the FSAR.
Such a transient would be much more severe than one caused by operation of a pneumat-ically-operated valve.
The main steam isolation valves are held open by compressed air.
Closure of these valves during operation is a less severe transient than the complete loss of all unit AC power, a transient analyzed in the FSAR.
A feedwater line break resulting in complete loss of feedwater has been analyzed which is a more severe condition than could be caused by an air system failure to the feedwater system.
Air-operated valves in the makeup system control system flow to the reactor coolant pump seals, makeup to the reactor, let-down flow, and boron dilution.
From the standpoint of a transient, the most important failure would be to cause dilu-tion of the boron in the reactor coolant. The moderator dilu-tion accident has been analyzed in the FSAR, assuming the maximum flow rate from a makeup pump is unborated water.
This is the worst possible transient due to an air failure in the makeup system.
It is, therefore, concluded that fire effects on the instru-ment air system will not cause a transient more severe than those already analyzed in the FSAR.
QUESTION 2 5. P_REVENTING RECIRCULATION OF VENTILATION AIR Describe the separation between the air intakes and exhausts for normal and emergency ventilation systems and the provi-sions which prevent smoke from being drawn back into the plant.
RESPONSE
The control canplex air intake and exhaust are both on the roof separated by a distance of more than 40 feet.
U pon d e-tection of smoke in the inlet air, dampers close to shut off the inlet.
The intake for the auxiliary building ventilation system is on the south side of the building above elevation Taylor (FireProt)
D9
~
QUESTION 25. (Cont'd) 143', while the exhaust is from a point near the top of the cylindrical section of the containment. The intermediate building air intake is in the turbine building while the ex-haust is at the southwest corner of the intermediate building.
QUESTION 29. FIRE DETECTION SYSTEM DESIGN Provide design data for the automatic fire detection system in each fire area, including such items as type, number and location of the dete. tors; and signaling, power supply and supervision of the system.
Identify any deviation (s) from NFPA 72D.
RES PONSE:
The number, type and location of detectors in the existing fire detection system which covers general plant areas are listed in Table 5-2 of the Florida Power Corporation submittal entitled Fire Protection Program Review, June 1977 Additional descriptive information is given in Section 5.3.3.1 of that submittal, and in the response to Question 72.
QUESTION 33. FIRE HAZARD AT THE CONTAINMENT CABLE PENETRATION Identify the consequences on safe shutdown of a fire at the cable penetration area on either side of the containment.
RESPONSE
There are four separate cable penetration areas located approximately in the northeast, southeast, west and northwest directions from the center of the containment.
Equipment in the containment used for safe shutdown is primarily instrumentation for monitoring reactor power (neutron level), reactor coolant system parameters and steam generator parameters.
There are also a few motor-operated valves and the reactor building cooling unit fans which it may be desirable to operate.
REACTOR POWER MONITORS There are four power range reactor power channels, two intermediate range channels and two source range channels.
Cables serving these channels exit the containment through four separate penetrations at the northeast.
Each of the penetrations serves one power range channel and either one source range or one intermediate source range channel.
In addition, each of the penetrations serves a number of in-core instrument cables.
All cables in these pentrations are low energy (low voltage and/or low current levels).
Locations of these penetrations, other penetrations and cable trays are shown in the attached figure. The penetration ends are enclosed in metal boxes.
All cables for source, inte rmediate and power range channels enter and leave the penetration areas in conduit.
Taylor (FireProt)
D9
i QUESTION 33. (Cont'd)
Outside the reactor building, the in-core instrument cables are routed away from the penetrations in short lengths of co nd uit to a tray.
The loading is low in this instrument tray. There is also a tray containing control cables as shown in the figure.
This tray has a loading of about 29%, the loading diminishing toward the end of the tray.
Because of the separation between the control tray and the penetrations serving the nuclear instrument channels, a fire occurring in that tray would not cause loss of all channels.
( Although such a fire may be postulated, it is not considered to be credible due to the low energy level of the control circuits and the fire-resistive characteristics of the cable insulation.)
The cables within the Instrument Tray Number 368 will be coated, for a length of 15 feet, with a flame-retardant coating to assure that a postulated fire in the tray would not spread to all nuclear instrument pene tra tions.
These penetrations are located above the airlock. A large concrete shield structure is provided above and in front of the airlock.
This structure, which is below the penetrations, would tend to protect them from an exposure fire in the area.
Within the reactor building, the penetration and tray configuration is almost a mirror image.
However, all in-core instrument cables are routed away from the penetrations in a separate tray for each penetration.
The reactor power instrument cables are in conduit, as on the outside. The instrument tray beneath the penetrations has only six cables.
There are no major combustibles in the area during normal plant operation. This area is acceptable on the basis of the separation provided and the low fire hazard in the area.
OTHER INSTRUMENTATION Cable penetrations for instruments monitoring reactor coolant system and steam generator parameters are located in the northwest quadrant of the containment. These channels are under review in connection with the safe shutdown capability.
Additional information will be presented in connection with that review.
OTHER EQUIPMENT In addition to instruments, the reactor building fan assemblies, the decay heat valves and the letdown cooler isolation valves may also b useful (but not necessarily essential) in reaching safu shutdcwn.
Power to the three reactor building fan motors enters through penetrations in three different penetration areas. Thus, one penetration area fire would leave at least two operable fans.
Taylor (FireProt)
D9
QUESTION 33. (Cont' d)
There are two decay heat valves in series in the line from the reactor coolant system to the decay heut system.
Both are normally closed and both must be open for operation of the decay heat system.
Eigher of these valves could be disabled by fire or other cause.
This is no real detriment to shutdown since they are equipped with handwheels for manual operation and they would not be operated until late in the shutdown sequence, several hours after the reac ror trip and the start of shutdown.
There are inlet and outlet valves in the letdown lines to the le tdown cooler.
Both valves for one cooler are normally open and would remain in that position for normal operation of the makeup system during shutdown.
Cables for both inlet valves use one penetration and those for both outlet valves use another penetration.
This is acceptable since chese valves control letdown from the reactor coolant system and other valves are available outside containment to shut of f the let-down flow.
These valves are also equipped for manual opera-tion.
Moreover, le tdown flow is normally maintained but is not essential to providing makeup to the reactor coolant sys-tem.
QUESTION 37. RADIOLOGICAL CONSEQUENCES OF A FIRE Evaluate the radiological consequences of a fire in radwaste areas and areas containing contaminated materials such as fil-ter cartridges, s pent resin, e tc.
RESPONSE
The radwaste area and other plant areas may contain quantities of st ae covers, paper, clothing items, etc. which are contam-inated with small amounts of particulate activity.
In the event of a fire, the activity wauld either remain as an ash or would be mobilized as particulate contamination in the smoke.
The smoke would enter the plant ventilation system, be diluted by air from other areas of the plant and be removed through HEPA and charcoal filters.
The HEPA filters would remove almost all of the airborne particulate activity.
Spent reactor coolant purification resins are sluiced to the radwaste area where they are collected in closed metal con-tainers.
They are then dewatered and immediately solidified in the containers by a urea formaldehyde agent for off-site shipment and dis posal.
High-activity filter cartridges are remotely removed from the filters and placed in shielded metal containers for removal to the radwaste area.
There, they are placed in shielded containers and stored and, later, solidi-fled in urea formaldehyde or placed in shielded casks.
There would be no release of radioactivity from spent resins or fil-ter cartridges in the event of fire because of the way these items are contained and handled.
Taylor (FireProt)
D9
QUESTION 37. (Cont'd)
Tne potential consequence of a fire which consumes spent charcoal filters has been analyzed.
For this analysis, the very conservative assumption was made that the unit has operated with an Iodine-131 activity in the containment atmosphere of 9 x 10-9 Ci/ml (the maximum allowed by 10CFR20 for occupational exposure).
Operation under this unlikely condition concurrent with continuous operation of the reactor building purge system was assumed to continue until equilibrium activity of Iodine was reached on the purge system charcoal filters.
It was assumed that air flow through the filters was stopped and, one week later, the filter elements were removed from the system. The fire was assumed to occur immediately after removal.
It was then assumed that half the iodine inventory on the filters would be available for release, the balance being removed by plate-out and other processes. The smoke and fumes from the fire would mix with air from the other parts of the auxiliary building and then be exhausted through that building's filter system which was conservatively assumed to have a decontamination factor of 10 for iodine. The thyroid dose at the site boundary was then calculated based on the 2-hour accident X/Q value. The thyroid dose was found to be less than 0.001 rem.
This analysis demonstrated that the doses from credible fires affecing contaminated wastes would not endanger the health and safety of the public.
QUESTION 38.
Clarify Statement on 480 volt and D.C. power cable being in the same tray (5-11).
RES PONSE:
A single tray may contain A.C. power cables at 480v or below, and may alsa contain D.C. power cables. These power cables supply power to motor control centers, distribution panels, motors, and other major loads.
QUESTION 57.
Will all parts of the fire detection and signaling system, includirg individual fire detectors, continue to f unction if normal AC and DC power sources are interrupted?
Clarification is required.
RESPONSE
Power to the fire detection system which serves general plant areas (Table 5-2 of the liceu.ee's June 1977 submittal) is AC, taken from the plant distribution system.
During normal unit operation, the unit generator supplies power to this system through the unit auxiliary transformer.
In the event that power from this source is lost, the plant distribution system Taylor (FireProt)
D9
QUESTION 57. (Cont'd) automatically transfers to receive power from the unit startup transfo rmer.
The source of power to the un~.t startup trans-former is the Florida Power Corporation 23's KV system (Unit 3 power is transmitted via the FPC 500 KV s / stem).
DC power is supplied to detectors which actuate deluge valves and is discussed in the Response to Quertion 69 QUESTION 72.
Document that all portions of the fire signaling system are electrically supervised.
RESPONSE
Fire detection and automatic fire extinguishing systems are provided as discussed in Section 5.3.3 of the Florida Power Corporation submital entitled, Fire Protection Program Review, June 197 7.
As discussed therein, a fire detection system is provided to give the alarm in case of fire in specific plant areas.
Major components are the detectors, the central panel and the alarm bells.
Circuits between the detectors and the central panel are supervised, as are circuits between the central panel and the alarm bells.
An audible signal is given in the event of failure in the supervised circuits.
In addition to the super-vised control room bell, there is an annunciator panel which receives signals from the detection system.
These circuits are not supervised whichis allowable per NFPA-72D, Article 2441a.
Fire detection information given by the annunciator panel can be determined at the fire detection system panel also.
In addition to the detector systems, there are several deluge systems which have automatic detection and deluge initiation as their prime f unction.
On each of these, supervision is provided for the manual initiating device circuit, the deluge valve circuit, shutof f valve position and loss of power to the system. On all but the charcoal filter systems, the detector circuits are also supervised.
An audible signal and a control room alarm are given in the event of a failure in the super-vised circuits and a control room alarm is given in the event of loss of electrical power to the system.
SRP-4 FIRE BRIGADE TRAINING Staff Concern Basic trainirg is a necessary element in ef fective fire fight-ing operations. To operate effectively, the fire brigade must f unction as a team.
Taylor (FireProt)
D9
SRP-4 (Cont'd)
Staf f Positio_n Fire brigade training should include the following:
(1) Regular planned meetings held every three months which repeat the classroom instruction program over a two year period.
(2) Practice sessions at regular intervals, but not to exceed one year for each brigade member.
(3) Drills performed at regular intervals, but not to exceed three months for each brigade.
At least one drill per year to be performed on a "back shif t" for each brigade.
Each individual member of the fire brigade shall participate in at least two drills per year. A suf ficient number of these drills, not less than one per year for each brigade, abould be announced to determine the fire readiness of the plant fire brigade leader, fire protection system, and equipment. The minimum number of fire brigade drills conducted within a period of three months shall be equal to the number of operating shif ts at the station.
RESPONSE
Part 1:
See Res ponse P-5, Enclosure 1.
Part 2:
Each brigade member has at least one practice session per year.
Part 3:
Fire brigade drills will be performed at regular intervals not to exceed three months for each fire brigad e.
The minimum number of fire brigade drills conducted within a period of three months will be equal to the number of operating shifts at the plant.
Each individual member of the fire brigade will participate in at least one drill per year *.
At least one drill per year for each brigade will be unannounced.
- This is based on shift turnover, promotions, sick time, vacation and outages.
SRP-38 FIRE BRIGADE Staff Concern The present proposal for manning the fire brigade is not considered adequate to successfully combat the types of fires that could be expected to occur.
Taylor (FireProt)
D9
SRP-38 (Cont' d)
Staff Position A fully-trained five-man fire brigade should be provided.
Licensee disagreed with Staf f Position and will provide his written position
RESPONSE
Recently, the Florida Power nuclear staff researched the back-ground of the five-man fire brigade concept. The results indicate that there are two primary factors underlying this concept.
They are:
- 1) fire department precedent, and 2) equipment handling requirements.
The NRC position for a five-member fire brigade is contained in a memorandum of November 4, 1977, from F.G. Goller, and a similar recommendation from Brookhaven National Laboratory dated October 19, 1977.
Those memoranda indicate that the NRC position was partially based on fire department precedent.
Fire departments actually utilize several combinations of man-power in their engine companies, ranging from five in number, down.
For example, one department was queried about their use of a five-man response team.
The stated reasoning was that two trucks were operated by this five-man crew.
Some of the equipment, such as four inch diameter hand suction hose, re-quires at lensc two men to manipulate. None of the initial response fire fighting equipment in the Crystal River nuclear plant requires more than one man to handle.
NFPA Standards were also reviewed to determine if there was any guidance provided relevant to minimum staffing requirements for private fire brigades.
NFPA No. 27, Private Fire Brigades, states:
"The equipment that must be put into service at a fire will determine the number of men required for each operating unit or company into which the brigade is organized and the total number of ten needed in the brigade.
Operating units or companies may be composed of two or more men to operate a specific item of equipment, or a larger group to perform more complicated operations.
Each company should have a leader and each brigade should have a chief."
Another consideration is the availability of manual fire fighting equipment. Commercial fire companies must transport their equipment to the fire scene. Hoses, appliances and accessories must be transported by men when accessibility by apparatus is limited.
Manual fire fighting equipment at the Crystal River nuclear plant is strategically located throughout the plant so that equipment transportation, when necessary, is easily handled by one man.
Taylor (FireProt)
D9
SRP-38 (Cont'd)
Automatic fire detection and suppression systems also relate to fire brigade size.
Many in the fire service consider these systems to be the fire fighters' first line of defense (Florida State Fire College).
All key areas and areas of high fire loading are equipped with automatic detection / suppression systems.
During design operation, these suppression systems need no manual backup.
In a communication on December 19, 1977, several NRC staff positions were addressed by FPC nuclear personnel. We feel that these arguments remain valid at this time and are, therefore, presented here for restatemeat.
II.
Minimum Fire Brigade Shift Size The preseat staff position is that five (5) men is the minimum fire brigade shift size allowable. The following argument will address each of the key points of the staf f position and will demonstrate that a four (4) man fire brigade at CR #3 can effectively meet the fire brigade requirements for an initial attack.
Staff Position 1.
Majority of postulated fires are in enclosed, windowless structures.
FPC Position 1.
We agree the postulated fires are in enclosed,
windowless structures. We also contend that the area involved will be small due to plant construction and the fire loadings are small when compared to what is found in the professional fire service situations. We also contend that our Fire Brigade, because of training, familiarity with the plant, and the detailed fire analysis which has been performed for CR #3, will have much better knowledge of the area, type of fire, fir; loading, fire hazards and the best attack method for a particular fire within the plant than the career fire service cn their initial attack.
Staff Position 2.
This requires use of S.C.B. A. and ventilation equipment.
FPC Position 2.
We agree that S.C.B.A. would be required and that ventilation equipment may or may not be necessary at the time of initial attack or during the fire.
Taylor (FireProt)
D9
SRP-38 (Cont' d)
Staff Position 3.
Personnel Replacement Capability FPC Position 3.
We do not agree that personnel replacement capabil-ity is necessary for the initial attack team.
This assumes (a) a large fire has' occurred; (b) a esn is injured severely enough that he cannot f unction in any capacity at the fire scene. However, if we do assume a man is injured, we believe the remaining three members of the fire brigade can function to control a postulated fire until additional fire brigade members are available.
In fact, an effec-tive 1.5 inch hose stream can still be maintained in-service by only two men.
Staff Position 4.
Certain ft nctions must be performed for all fires:
(a) command brigade actions; (b) inform plant man-agement; (c) fire suppression; (d) ventilation con-trol; (e) provide extra equipment; (f) account for possible injuries.
FPC Position 4(a) One supervisor per shif t will be qualified and designated to be in charge of the initial attach team (will not be Supervisor of Operating Shif t).
4(b) Initially, plant management will be informed by the Shif t Supervisor. Follow-up fire scene reports will come during initial size-up and preparation to attack the fire.
These reports will be made to the Shif t Supervisor by the Fire Brigade Supervisor at the scene.
Secondary reports will be made after initial attack has begun and assessment of its effectiveness is possible.
Reports will then be in-termittent as conditions change. This would mean that the fire brigade supervisor would need to spend only short periods of time in communications during the initial attach which would free him to perform or assist in the performance of additional tasks.
4(c) The safety related areas with the highest fire load-ing (Cable Spreading Room, Emergency Diesel Genera-tor Room, Charcoal filter banks) have automatic fire suppression systems. These systems are maintained functional by numrous surveillance procedures which ensure an extremely high reliability factor.
If an Taylor (FireProt)
D9
SRP-38 (Cont'd)
Staff Position automatic supression system fails to actuate, which is highly improbable, or if the fire is located in an area without automatic suppression systems, then the primary fire suppression method is assumed to be a 1.5 inch fire hose manned by two individuals.
This hose team would be provided with S.C.B. A. and backed up with an available charged hose.
4(d) One man may be required to establish ventilation.
In most cases, the primary ventilation provided would be forced draf t ventilation using eductors.
This would be supplied to the scene upon initial arrival. This f unction, if necessary, can be accomplished rapidly, freeing this man for other tasks.
4(e) FPC is providing fire carts which will have extra hose, nozzles, eductors, foam, forcible entry tools, portable lights, and extra air bottles for S.C.B.A.
These will be brought to the scene upon the initial attack.
This is to keep from sending a man af ter extra equipment.
4(f) If possible injuries do occur, there is no reason why the fire brigade supervisor could not help in this situation, keeping in mind the limited area involved in a postulated fire, the close vicinity of all four men, and the fact that professional fire companies sometimes use the company officer as backup man on a second hose team, directing the company from that position.
Staff Position 5.
If the brigade is composed of a smaller number of personnel (less than five), the fire attack may be stopped whenever (a) new equipment is needed or (b) a person is injured or fatigued.
(c) We note that in the career fire service, the minimum engine company manning considered to be effective for an initial attack on a fire is also five.
FPC Position 5(a) We don't anticipate the initial attack team will require any equipment other than what will be contained on the fire carts which will be brought to the fire scene initially.
Taylor (FireProt)
D9
SRP-38 (Cont'd)
FPC Position 5(b) If one man is injured, he can be replaced in a short period of time.
Upon receipt of the fire alarm, we would initiate the callback of additional of fsite fire bri ade members.
During a recent unannounced d
drill, the response time was 22 minutes for the first member to arrive at the scene in full turnout gear.
During the interim, a 1.5 inch hose will still be manned with an ef fective stream by two men with the command and communication function being performe by the third member.
5(c) We note that in the career fire service five-man pumper company, one man is required as a Driver Engineer. This primary purpose is to maintain water preseure while remaining with the engine.
We do not need this function at a power plant. We also will not need to lay the amount of hose required of a pumper company. The four-man fire brigade pro-posed by FPC cm.n perform the same f unctions as the remaining four members of a pumper company.
Staff Position 6.
One Supervisor - This supervisor snould not be actively engaged in the fighting of the fire.
His total function should be to survey the fire area, command the brigade, and keep the upper levels of management informed.
FPC Position 6.
We do not believe the supervisor should be actively engaged on the 1.5 inch hose team. However, there is no reason to believe he cannot function to (a) survey the fire area (which due to three hour rated fire walls will be limited); (b) command the brig-ade; (c) keep upper levels of management informed, while performing simple tasks such as changing air bottles and passing in equipment.
Staff Position 7.
Two Hose Men - A 1.5 inch fire hose, being handled within a windowless enclosure, would require two trained individuals.
The two team members are re-quired to physically handle the active hose line and to protect each other while la adverse environment of the fire.
Taylor (FireProt)
D9
SRP-38 (Cont'd)
FPC Position 7.
We agree that two are needed to ef fectively handle and manuever a 1.5 inch hose and provide each other protection while fighting the fire.
Staff Position S.
Two Additional Team Members - One of these individuals would be required to supply filled air cylinders to the fire fighting members of the brigade and the second to establish smoke ventilation and aid in filling the air cylinders.
These two individuals would also act as the first backup to the engaged tea =.
FPC Position 8.
FPC has 10 S.C.B. A. 's filled at all times and ready to be used in a fire situation and for no other purpose. We also have 11 full back-up bottles.
A sufficient number of these filled air bottles will be provided on the fire carts and brought to the fire scene during the initial response.
We cannot foresee having to charge any air bottles until af ter other members of the fire brigade have arrived.
One man can establish forced ventilation when needed in an expeditious manner as stated earlier.
He would then be free to perform other tasks, such as supplying air cylinders to the hose team.
The back-up function can be maintained by the one individual who established ventilation and the fire brigade supe rvisor.
III.
Conclusion Based on the above discussion, it is our opinion that a four-man fire brigade at Crystal River Unit 3 can perform all of the required functions identified in your Staff Position, i.e. command brigade actions, inform plant management, fire suppression, ventilation control, provide extra equipment, and account for possible injuries.
QUESTION 72. (NOVEHBER 21, 1978 Le tter)
Confirm that the following provisions of NRC's document "huclear Plant Fire Protection Functional Responsibilities, Administrative Controls and Quality Assurance" are met or provide justification for any exceptions:
Taylor (FireProt)
D9
QUESTION 72. (Cont'd) a.
Fire fighting procedures are documented and include strategies for fighting fires in all safety related areas and areas presenting a hazard to safety related equipment.
b.
Documented fire fighting strategies include the subjects covered in subsection d(1) through d(10) of Attachment 5 to the above document.
c.
Administrative procedures have been established to ensure a periodic inspection for accitmulation of combustibles.
d.
Administrative procedures have been established to ensure that all wood used in safety related areas is treated with a flame retardant.
e.
Administrative procedures have been e stablished which ensure that open flame or combustion smoke for leak testing is prohibited.
f.
Administrative procedures require thut the person (s) responsible for physically surveying the work area and issuing the hot work pe rmit has eceived a basic industrial fire fighting and fire prevention course.
g.
Administrative procedures relative to propcsed work activities required a review to identify potential transient fire loads which exceed the capacity of the installed fire suppression system and that portable suppression equipment shall be brought into the area.
h.
The Quality Assurance provisions established for fire protection will fully implement the QA criteria of Appendix A to BTP 9.5-1.
RESPONSE
a&b General fire fighting strategy for all areas of the plant is documented in Emergency Procedure EM-216.
S pecific strategies for postulated fire emergency situations are covered in detail by pre plan fire drill activities.
This method reinforced fire fighting attack flexibility which is essential for speedy extinguishment and efficient overhaul of any fire area. Types of fires, fuels, extinguishants and extinguishment techniques are presented in the fire brigade training course at CR-3.
This training includes all types of fire conditions and fire fighting techniques.
c.
Inspection for combustibles is documented in Procedure EM-216, " Duties of the Nuclear Plant Fire Brigade" section 3.3.b.
d.
Emergency Procedure EM-101, " Fire Protection Plan",
documents the use of fire retardant wood in the plant.
Taylor (FireProt)
D9
4 QUESTION 72. (Cont'd)
Emergency Procedure EM-101, " Fire Protection Plan",
e.
insures that open flame and combustible gases are not used in leak testing.
f.
Emergency Procedure EM-101, " Fire Protection Plan",
requires that the person (s) responsible for physically surveying the work area and issuing the hot work permit has received a basic industrial fire fighting and fire prevention course.
g.
Compliance Procedure CP-118, " Fire Prevention Work Permit Procedure" requires a review to identify potential transient fire loads associated with proposed work activities, and that adequate portable fire suppression equipment shall be brought into the area where work is to be pe rfo rmed.
h.
Florida Power Corporation has developed and implemented a total quality program covering the design, procurement, manufacturing, construction, testing, operation, maintenance and modification of plant components and systems.
Elements of the quality assurance program will be applied as required.
This program and its application to fire protection are described in Section 3.3 of the
" Fire Protection Program Review", Docket No. 50-302.
The program meets the intent of the requirements of the Appendix to the Branch Technical Position.
P-5 (NOVEHBER 21, 1978 LETTER)
Section 1.0 under Fire Brigade Training of the Licensee's respouse to Attachmen 2 of " Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls and Quality Assurance", states that the proposed frequency of classroom training will be once per year on a staggered basis.
The proposed frequency for fire brigade classroom instruction (annual) does not provide adequate training to assure personnel familiarization with the fire hazards, fire fighting equipment and tactics to be used in suppressing fires manually.
NRC Position Provisions should be made for regular planned meetings, held every 3 months, to repeat the classroom instruction program within a two year period.
RESPONSE
An updated Fire Brigade training program was initiated in January, 1979.
It now consists of repeated classroom instruction four times per year.
All fire fighting subjects are repeated at least once per two year period.
Taylor (FireProt)
D9