ML19317F686
| ML19317F686 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 03/22/1978 |
| From: | Engle L Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML19317F680 | List: |
| References | |
| NUDOCS 8001230585 | |
| Download: ML19317F686 (8) | |
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SAFEI"I EVALUATION BY THE Q.'FICE OF NUCLEAR REACTOR REGULATION SUPPORTING Af4ENDt1ENT NO. 9 'IO LICENSE NO. NPF-3 TOLEDO EDISON CCt4PANY AND CLEVELAND ELECTRIC ILLUMINATING CQ4PANY 9
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IrrITODUCTION Following a fire at the Brown's Ferry Nuclear Station, t.he Nuclear Regulatory Commission initiated an evaluation of the need Mr improving the fire protection programs at all licensed nuclear power plants. As part of this continuing evaluation, the NFC, in February 1976, published _
the report by a special review group entitled " Recommendations Related to Browns Ferry Fire," NUREG-0050. This report recommended that improve-ments in the areas of fire prevention and fire control be made in most existing facilities and that consideration be given to design features that would increase the ability of nuclear facilities to withstand fires without the loss of important functions.
"o implement the report's reccamendations, the NRC initiated a program for reevaluation of the fire protection programs at all licensed nuclear power stations, and for a comprehensive review of all license applications.
The NRC issued new guidelines for fire protection programs in nuclear power plants which reflect the recomr.endations in NUREG-0050. These guidelines are contained in the following documents:
- Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants," NUREG 75/0d7, Section 9.5.1, Fire Protection, itay 1975, which includes " Guidelines for Fire Protection for Nuclear Power Plants," (BTP-APCSB 9.5-1), May 1, 1976.
- " Guidelines for Fire Protection for Nuclear Power Plants," (A@endix A to BTP-APCSB 9.5-1), August 23, 1976.
- " Supplementary Guidance on Information Needed for Fire Protection Program Evaluation," September 30, 1976.
" Sample Technical Specifications," May 12, 1977.
" Nuclear Plant Fire Protection Functional Responsibilities, Adminis-trative Controls and Quality Assurance," June 14, 1977.
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. By letters dated February 11, 1977 and January 11, 1978 the Toledo Edison Company submitted the Fire Hazard Analysis Report for Davis Besse, Unit 1 and Revision No.1, thereto, respectively. Revision No. 1 is presently under detailed review by the NRC staff. In the interim, until we complete our detailed review, we have concludcd that it is appropriate to implement operability and surveillance requirements for the existing fire protection equipment and systems at Davis Besse, Unit 1 by incorporating these requirements in the Technical Specifications. Also, we are including administrative requirements for the implementation of the fire protection program.
By letter, dated November 28, 1977 we issued sample Technical Speci-fications as guidance to the Toledo Edison Company and requested that the Toledo Edison Company subnit Technical Specifications for the cresently installed fire protection equipment at the facility.
By letter dated December 12, 1977 the Toledo Edison Company submitted proposed interim Technical Specifications. We have reviewed the pro-posed Technical Specifications and made several modifications to assure conformance to the fullest extent practicable with our requirements as set forth in the sample Technical Specifications pending completion of our ongoing detailed review of fire protection at this facility.
DISCUSSICN AND EVAIL% TION The guidelines for Technical Specifications that we developed and sent to all licensees are based on assuring that the fire protection equipment currently installed for the protection of safety-related areas of the plant is operable. This assurance is obtained by requiring periodic surveillance of the equipment and by requiring certain corrective actions to be taken if the limiting conditions for operation cannot be met. These guidelines also include adminis-trative features for the overall fire protection program such as interim fire brigade requirements, training, procedures, management review and periodic independent fire protection and loss prevention-program inspections.
The equipment and comoonents existing at Davis Besse, Unit 1 and included in the sccpe of these Technical Specification requirements are fire detectors, the fire suppression systems, the hose stations, and penetration fire barriers for piping and caoling penetrations.
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. Operability of the fire detection instrumentation provides warning capability for the prompt detection of fires to reduce the potential for damage to safety-related equipment 'oy allowing rapid response of i
fire suppression systems. In the event that the mininum coverage of fire detectors cannot be mt, hourly fire patrols are required in the t
affected area until the inoperable instrumentation is restored to operability. The operability of the fire suppression systems provides capability to continue and extinguish fires. In the event that portions of the fire suppression systems are inoperable, alternate backup fire fightnig equipment is required to be made available in the affected areas until the inocerable equipment is returned to service. In the event that the fire suppression water system becomes inoperacle, a backup fire protection water system is required within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and a report to the NRC is required within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to provide for prompt eval-uation of the acceptability of the corrective measures for adequate fire suppression capability. The functional integrity of the penetration fire barriers provides protection to confine or retard fires from spreading to adjacent portions of tne facility. During perious of time when a fire barrier is not functional, a continuous fire watch is required to be maintained in the vicinity of the affected barrier to provide fire prevention methods and prompt detection and suppression in the event of a fire.
We have now reviewed the licensee's proposed interim Technical Specifi-cations against our requirements as implemented in the sample Technical 3pecifications. he have made some modifications to the specifications that were proposed by the licensee in order to make them conform to our requirements. These modifications have been agreed to by the Toledo Edison Ccmpany.
In our sartple Technical Soecifications which were sent to the Toledo Edison Company, on Nove:rber 28, 1977 we identified a minimum number of 5 merrt>crs for the facility fire brigades as being acceptable. Our basis for the minimum nunter of five m2mcers is presented in Acpendix A to this safety Evaluation. The Toledo Edison Company initially proposed a minimum fire brigade size of two persons and subsequently modified the minimum fire brigade si;:: to three persons and has not agreed to a minimum fire briga Je si;:e of five. We are requesting the Toledo Edison Company to agree or disrJree in writing with our pcsition, and if the Toledo Edison Cortpany disagrees, to state their reasons and the technical basis therafor.
In the interim, to expedite inplementation of a fire brigade, we are issuing Technical Scecifications with a fire brigade size of three persons as proposed by the licensee.
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, In the report of the Special Review Group on the Browns Ferry Fire (GUPEG-0050) dated February 1976, consideration of the safety of operation of all operating nuclear power plants pending the completion of our detailed fire protection evaluation was presented. The following quotations from the report summarize the basis for our conclusion that the operation of the facility, pending resolution of the incomplete items and the inplementation of all facility modifications, does not present an undue risk to the health and safety of the public.
"A probability assessment of public safety or risk in quantita' 9
terms is given in the Peactor Safety Study ('dA5H-1400). As th result of the calculation based on the Browns Ferry Fire, the study concludes that the potential for a significant release of radio activity from such a fire is about 20% of that calculated from all other causes analyzed. This indicates that predicted potential accidental risks from all causes were not greatly affected by con-sideration of the Browns Ferry fire. This is one of the reasons that urgen: action in regard to reducing risks due to potential fires is not rtquired.
The study (WASH-1400) also points out that 'rather straisntforward measures, such as may already exist at other nuclear plants, can significantly rcJuce the likelihocd of a potential core treit accident that might result from a lar 7 fire.'
" Fires occur rather frequently; however, fires involving equipment unavailability comparable to the Browns Ferry fire are quite infrequent (see Section 3.3 of NUREG-0050). The Review Group believes that steps already taken since Marca 1975 (see Section 3.3.2) have reduced this frequency significantly.
" Based on its review of the events transpiring before, during and af ter the Growns Ferry fire, the Review Group concludes that the probability of disruptive fires of the magnitude of the Browns Ferry event is s. mall, and that there is no need to restrict operation of nuclear, cower plants for public safety. However, it is clear that much cra and snould be done to reduce even further the likelihood of dissoling fires and to improve assurance of rapid extinguish-ment of fires that occur. Consideration should be given also to featurcs that would increase further tne ability of nuclear fac.ilities to withstand large fires without loss of i::portant functicas should such fires occur,"
As stated in our 3afety Evaluation Recort and Supplement No.1 thereto, we reaffirm our conclusions that, based upon cur review ~of the Davis Besse, Unit 1 fire protection design we conclude that for the interim, the facility fire protection system is acceptable.
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. nierefore, we find these specifications to be acceptable on an interim basis until such time that our detailed review of the Davis Besse, I' nit 1 Fire dazards Analysis Report is cceplete, any required modificatias based upon our review are cc::oleted, and final specifications have been developed and issued.
UN11GitENTAL CONSIDFRATICri We nave determined that tne license amendment does not authorize a change in efflunt types or total amounts nor an increase in power icvel ana will not result in any significant environmental 1.mact.
daving nade tnis determination, we have furt.her concitxied tnat the exencrant involves an action wnich is insignificant frca the stand-point of envircnmental imcact and pursuant to 10 CFR 51.5(d)(4) that an envirentrental inpact stateJent, or negative declaration and environmental impact appraisal need not be prepared in connection.
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CONCI2510t!
.ie have concluded, sased on tne censicerations discussed acove, that (1) occause the ax.cairent coes net involve a significant increase in the probability or consequences of accidents previously considered and coes not involve a significant hazards censideration, (2) tacre 1.s reasoncble assurance that the nealth and safety of tne puclic will not ce endangered by operation in the proposed mannce, and (3) sucn activities will be conducted in coi pliance with tne Ccenission's regulations and the issuance of this arend: rent will not be inimical to the coraaon defense and security or to the healtn and safety of the puclic. Also, we reaffirm our cenclusions as otherwise stated in our Safety Evaluation Pcocrt.
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APPDIDIX A Staff Position
!!inimum Fire Brigade Shift Size IhTRODUCTICri Nuclear power plants depend on the response of an onsite fire brigade for defense against the effects of fire on plant safe shutdown capa-bilities. In some areas, actions by the fire brigade are the only means of fire suporessicn. In other areas, that are protected by correctly designed automatic detection and suppression systems, manual fire fighting efforts are used to extinguish:
(1) fires too small to actuate the automatic system; (2) well developed fires if the automatic system fails to function; and (3) fires that are not completely controlled by the automatic system. Thus, an adequate fire brigade is essential to fulfill the defense in depth require-ments which protect safe shutdown systems from the effects of fires and their related combustion byproducts.
DISCUSSIQi There are a number of factors that should be considered in establishing the minimum fire brigade shif t size. They include:
- 1) plant geometry and size;
- 2) quantity and quality of detection and suppression systems;
- 3) fire fighting strategies for postolated fires; I
- 4) fire brigade training;
- 5) fire brigade equipment; and
- 6) fire brigade supplements by plant personnel and local fire department (s).
In all plants, the majority of postulated fires are in enclosed window-less structures.
In such areas, the working environment of the brigade created by the heat and c oke buildup within the enclosure, will require the use of self-contained breathing apparatus, smoke ventilation equip-ment, and a personnel replacement capability.
Certain functions must be performed for all fires, i.e., command brigade actions, inform plant management, fire suppression, ventilation control, provide extra equipment, and account for possible injuries. Until a site cpecific review can be completed, an interim minimum fire brigade size of five persons has been established. This brigade size should provide a minimum working nu:ter of personnel to deal with those postulated fires in a typical presently operating commercial nuclear power station.
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. If the brigade is composed of a smaller number of personnel, the fire attack may be stoprAd whenever new equipment is needed or a person is injured or fatigued. 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, including one officer and four team menbers.
It is assumed for the purposes of this position that brigade training and equipment is adequate and that a backup capability of trained individuals uist whether through plant personnel call back or from the local fire department.
POSITICH 1.
The minimum fire brig /ide shift size should be justified by an analysis of the plant specific factors stated above for the plant, after modifications are complete.
2.
In the interim, the minimum fire brigade shif t sise shall be five persons. These persons shall ce fully qualified to perform their assigned responsibility, and shall include:
One Suoervisor - This individual must have fire tactics training.
Ele will assume all command responsibilities for fighting the fire.
During plant emergencies, the brigade supervisor should not have other responsibilities that would detract from his full attention being devoted to the fire. This supervisor should not be actively engaged in the fighting of tne fire. His total function should be to survey the fire area, cor.cand the brigade, and keep the upper levels of plant management informed.
To flose Man - A 1.5 inch fire hose being handled within a window-less enclosure would recuire two trained individuals. The two team menters are requirdd to physically handle the active hose line and to protect each other while in the adverse environment of the fire.
To Additional Team Members - Cne of these individuals would be requied to supply filled air cylinders to the fire fighting members of the brigade and the second to establish smoke venti-lation and aid in fillinJ the air cylinder. These two individuals would also act as the first backup to the engaged team.
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