ML19319D204
| ML19319D204 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 06/23/1978 |
| From: | Ormston A FLORIDA POWER CORP. |
| To: | Stello V Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8003130803 | |
| Download: ML19319D204 (4) | |
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REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)50-302 DISTRIBUTION FOR INCOMING MATERIAL
'.C : STELLO V ORG: ORMSTON A J DOCDATE: 06/23/7S DATE RCVD: 06/26/78 NRC FL PWR COPIES RECEIVED iCTYPE: LETTER NOTARI7ED: YES LTR 3 ENCL 0 fBJECT:
IRNISHING COMMENTS AND POSITIONS FROM REVIEW OF NRC GUIDANCE DOCUMENT ITITLED: " MANPOWER REQUIREMENTS FOR OPERATING REACTORS", RE POSITION ON THE
- NIMUM FIRE ERIGADE SIZE.
NOTARIZED 06/23/78.
REVIEWER INITIAL:
XJM
_ ANT NAME: CRYSTAL RIVER #3 DISTRIBUTOR INITIAL:g4
- ooooo********** DISTRIBUTION OF THIS MATERIAL IS AS FOLLOWS ******************
J FIRE PROTECTION INFORMATION (AFTER ISSUANCE OF OL).
(DISTRIBUTION CODE AOO6)
FOR ~ ACTION':
BR CHIEF ORB #4 BC**LTR ONLY(4)
INTERNAL:
EG F
_**LTR ONLY(1)
NRC PDR**LTR ONLY(1) m**LTR ONLY(2)
OELD**LTR ONLY(1)
AUXILIARY SYS BR**LTR ONLY(2)
AD FOR SYS & PROJ**LTR ONLY(1)
PLANT SYSTEhd BR**LTR ONLY(5)
WAMBACH**LTR ONLY(1)
. R.
MURANKA**LTR ONLY(1)
HANAUER**LTR ONLY(1)
EXTERNAL:
LPDR'S CRYSTAL RIVER, FL**LTR ONLY(1)
TIC **LTR ONLY(1)
NSIC**LTR ONLY(1)
ACRS CAT B**LTR ONLY(16) vC.
3ISTRIBUTION:
LTR 39 ENCL 0 CONTROL NBR:
9999553h4 SIZE: 3P
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. June 23,1978 Mr. Victor Stello, Jr.
Director, Division of Operating Reactors Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Silbject: Crystal River IJnit 3
-3d Docket No. 50-302 Operating License No. DPR-72
Dear Mr. Stellc:
Your letter of June 5,1978 requested that Florida Power Corporation review the NRC guidance document entitled " Manpower Requirements for Operating Reactors" and inform you if we continue to object to your position on the minimum fire brigade size.
On December 19, 1977 Florida Power Corporation responded to the Commission's letter of November 29, 1977 concerning the proposed interim Technical Specifications which would require that a minimum of 5 members of the CR
- 3 Fire Brigade be on site at all times.
It was our position at that time that a 4 man Fire Brigade at CR #3 could perform all of the functions identified in the Staff's position on minimum fire brigade shift size. The justification for our position on minimum fire brigade size was contained in our December 19, 1977 submittal.
As a result of this submittal the Commission issued Amendment No.13 to the CR #3 Operating License on February 3,1978 which contained Technical Specifications regarding fire protection systems and administrative controls at CR #3. As part of this Amendment, Technical Specification 6.2.2.f required that a minimum of 4 members of the CR #3 Fire Brigade be on site at all times.
We have completed our review of the above referenced NRC guidance document and wish to state the following comments and/or positions:
1)
Your June 5,1978 letter contained as Attachment A, a reiteration of the Staff's basis for the need for a five-man fire brigade.
Although your' guidance document offers additional information n
S.
General Office 32o1 ining-tounn street soutn. P O Box 14042. St Petersburg. Florica 33733 e 813-866 5151
1 l
Mr. Stello Page Two June 23, 1978 concerning the staffing of the fire brigade by plant personnel from either the operations or security organizations, no additional technical justifications or factors that should be i
considered by FPC in establishing the minimum fire brigade size were proposed by your staff.
2)
Florida Power Corporation agrees with the staff's conclusion that for most events a minimum of 3 operators should be available to place the reactor in a safe condition. All 5 members of I
the minimum shift crew are only needed to shutdown the plant from outside the Control Room.
If the fire occurs in a location where shutdown from outside the Control Room is not required, then only 3 operators are required '.o safely shutdown the plant.
In this case, two additional operators would be free to respond to the fire. Therefore, the minimum shift crew of 5 should be qualified as only applicable when shutdown from outside the Control Room is required.
3)
Although we agree that security personnel should not be totally excluded from participation on the fire brigade, it is not presently FPC's intent to use members of the CR #3 security organization on the fire brigade. Their participation on the fire brigade would necessitate extensive fire fighting training which is not practical in light of the high turnover of security personnel. We co feel that the security organization could assist the fire brigade during a fire emergency by aiding injured personnel and oroviding additional equipment to the fire brigade upon request Based on the above discussion, the lack of any new technical justification by the NRC for a 5 man fire brigade and our submittal of December 19, 1977, it is still Florida Power Corporation's position that a 4 man fire brigade at CR #3 can perform all of the required functions identified in your staff position, i.e., command brigade action, info'm plant management, fire suppression, ventilation control, provide extra equipment, and account for possible injuries.
If you wish to discuss further our position on this matter, please do not hesitate to contact this office.
Very ' truly yours, FLORIDA POWER CORPORATION-1 s
..~s A. J. Ormston, Vice President AJ0/hw 5/13a File: 3-0-3-e b
~
STATE OF FLORIDA
. COUNTY OF PINEllAS A. J. Ormston, Vice President for Florida Power Corporation, states that he is authorized on the part of said company to sign and file with
, the Nuclear Regulatory Commission the information attached thereto; and that all such statements made and matters sat forth therein are true and correct to the best of his knowledge, information and belief.
l.
A. J. Ormston,
Subscribed and sworn to before me, a Notary Public in and for the State and County above named, this 23rd day of June,1978.
~
Notary Public Notary Nblic,, += of Ffo.id-et twen*
My Comen;ssion Erpires Aug. 24,1?*?
Bondad by Amerien Fire & Coni,unf Co.
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