ML19289E333
| ML19289E333 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 03/14/1979 |
| From: | Randy Hall BROOKHAVEN NATIONAL LABORATORY |
| To: | Ferguson R Office of Nuclear Reactor Regulation |
| References | |
| CON-FIN-A-3107 NUDOCS 7904110160 | |
| Download: ML19289E333 (4) | |
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~ _J L;J Upton, New York 11973 Deportmentof NuclearEnergy (516) 345 2362 flarch 14, 1979 Division of Operating Reactors U. S. Nuclear Regulatory Commission (gk h ggd \\60 Washington, D. C.
20555 Attention: Mr. Robert L. Ferguson h
}ggif@ NCo M UI5 I
Plant Systems Branch
Dear Bob:
Subject:
Fire Protection in Operating Nuclear Power Stations Big Rock Point Safety Evaluation Report Review The Safety Evaluation Report, as developed jointly by the NRC staff and Brookhaven National Laboratory (BNL) adequately reflects the concerns and rec-ommendations of the consultants.
Throughout the reevaluation of Big Rock Point, there has been general agreement between the NRC staff and the BNL consultants.
Based on present data, the proposed fire protection, as set forth in the SER, will give reasonable assurance that the health and safety of the public is not endangered. The following exception represents a differing engineering point of view that should be evaluated by the NRC staff:
Turbine Building SER Item 5-10 concludes that fire protection in the turbine-generator build-ing is acceptable.
However, the licensee's fire hazard analysis does not ade-quately address the consequences of an unsuppressed lube oil fire in the turbine building (see October 24, 1977 letter from L. P. Herman to R. E. Hall on this subject).
Valve Supervision SER Item 4.3.1.3 indicates that the position of fire protection system valves will be controlled by locks or seals with periodic inspection.
Locking or sealing programs depend upon ongoing administrative controls that are subject to human failure. Locks can also prevent prompt water shutoff if piping ruptures.
It is recommended that electrical supervision be required on all control valves for fire protection systems protecting areas containing or exposing safety-related equip-ment.
Smoke Removal SER Item 4.4.1 indicates that portable fans and ducts will be accepted as a means for removing smoke from many plant areas.
Fires in electrical insulation can generate copious amounts of dense smoke which hamper fire control efforts by 79041101@
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- rendering the atmosphere toxic and reducing visibility in the area.
Properly used, self-contained breathing apparatus can minimize the problem of toxic at-mosphere, but little can be done to improve visibility except to remove the smoke from the building.
Massive changes will be required in most areas of this plant if effective permanent smoke removal systems are required, the design of which would also have to include consideration of radioactivity releases.
While portable fans and ducts may be effective for smoke control in many instances, there is concern that they will not be sufficient for a major fire in some areas of the plant.
It is recommended that this item be held open until better guidelines are developed for the evaluation of smoke generation potential and smoke removal system design.
Breathing Apparatus SER Item 3.1.11 does not establish a minimum required number of breathing apparatus units. We recomend that the licensee provide an aimrgency breathing capability sufficient to supply 8 men for 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> at the rate of 3 air bottles per hour per man, using bottles rated at 30 minutes each.
The preceding statements are based on a detailed reevaluation of the fire pro-tection program as implemented by the Consumers Power Company (CPC) at the Big Rock Point Nuclear Power Station.
The analysis covered a review of the fire prevention, detection and suppression capabilities of the plant, as interfaced with the nuclear systems requirements.
This was accomplished by utilizing a review team concept with memb'ers from Brookhaven National Laboratory (BNL) and the Nuclear Regulatory Comission Division of Operating Reactors staff.
The fire protection evaluation for the Big Rock Point Plant is based on an analysis of documents submitted by the Consumers Power Company to the Nuclear. Reg-ulatory Commission and a site visit. The site visit was conducted by fiessrs. J. E.
Knight and H. J. George of the NRC, Mr. L. P. Heman of Rolf Jensen & Associates, Inc. under contract 'co Brookhaven National Laboratory, and Mr. J. Riopelle, con-sultant to BNL.
Mr. Riopelle was under contract to BNL to review the manual fire fighting capabilities of the station along with administrative controls.
Milestone Dates 1.
The CPC " Fire Protection Program Evaluation" was transmitted to NRC on March 29, 1977.
2.
On fiarch 3,1978, NRC transmitted Staff Positions and Requests for Additional Information based on an initial review of the CPC sub-mittal.
3.
The site visit was conducted on October 10-13, 1978. The primary Review Team consisted of James E. Knight and Henry J. George of the NRC staff, James Riopelle, private consultant, and L. Paul Herman of Rolf Jensen & Associates, Inc. Mr. Knight served as team leader and spokesman.
1' 9 4.
On July 14, 1978, CPC transmitted a response to the initial Staff Positions and Requests for Additional Information.
5.
On October 6, 1978, CPC transmitted responses to portions of the Staff Positions and Requests for Additional Information.
6.
On October 27, 1978, NRC transmitted further Staff Positions and Requests for Additional Information based on the site vis't.
7.
On December 8, 1978, January 17, 1979, and February 12, 1979, CPC transmitted responses to portions of the Staff Positions and Requests for Additional Inf9rmation.
8.
Tha SER draft associated with this report is attached to an NRC memo from G. Lainas to D. Ziemann dated February 5, 1979.
Review Cocuments The following docements were used in the Big Rock Point fire protection re-view:
1.
NRC Branch Technical Position APCSB 9.5-1, Appendix A, dated August 23, 1976.
3.
" Fire Protection Program Evaluation", dated March 29, 1977, by Consumers Power Company.
3.
CPC responses to Staff Positions and Requests for Additional In-formation, dated July 14, 1978, October 6, 1978, December 8, 1978, January 17, 1979, and February 12, 1979.
4.
Drawing:
M-123(16)
The Big Point Rock review has been conducted under the direction of Mr. E. A.
MacDougall and myself of Reactor Engineering Analysis Group at BNL.
We have reviewed the analyses submitted by the licensee and have visited the facility to examine the relationship of safety-related components, systems and structures with both combustibles and the associated fire detection and suppression rystems. Our review has been limited to the aspects of fire protection related to the protection of the public frcm the standpoint of radiological health and safety.
We have not considered aspects of fire protection associated with life safety of onsite personnel and with property protection, unless they impact the health and safety of the public due to the release of radioactive material.
The proposed modifications represent a significant increase in the level of protection against serious fire associated hazards.
Respectfully yours, obert E. Hall, Group Leader Reactor Engineering Analysis REH/EAM:dt
V It:TERIM REPORT MRC ReS0?JCDhychn\\C3\\\\
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Contract Program or Project
Title:
Fire Protection in Operating Nuclear Power Stations Subject of this Document:
Big Rock Point Safety Evaluation Report Review Type of Document:
Letter Report Author (s):
Robert E. Hall Date of Document:
March 14, 1979 Responsible NRC Individual and NRC Office or Division:
Mr. R. L. Ferguson Division of Operating Reactors U. S. Nuclear Regulatory Commission Washington, D. C.
20555 This document was prepared primarily for preliminary or internal use.
It has not received full review and approval.
Since there may be substantive changes, this document should not be considered final.
Brookhaven National Laboratory Upton, NY 11973 Associated Universities, Inc.
for the U.S. Department of Energy Prepared for U.S. Nuclear Regulatory Commission Washington, D. C.
20555 Under Interagency Agreement EY-76-C-02-0016 NRC FIN No. A 3107 INTERIM REPO,RT' O~'s " -i N10;i 00 n~
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