ML19319E082
| ML19319E082 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 06/26/1978 |
| From: | Mattimoe J SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| To: | Stello V Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8003310592 | |
| Download: ML19319E082 (7) | |
Text
A o 4 Jo 78 o
z REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
DISTRIBUTION FOR INCOMING MATERI AL - -
50-312 REC: STELLO V ORG: MATTIMOE J J DOCDATE: 06/26/78 NRC SACRAMENTO MUN UTIL DIST DATE RCVD: 06/29/78 DOCTYPE: LETTER NOTARIZED: NO COPIES RECEIVED
SUBJECT:
LTR 1 ENCL 0 FURNISHING ADDL COMMENTS AND OBJECTIONS TO APPLICANT"S PREVIOUS LTR IN RESPONSE TO NRC LTR DTD 06/05/78 CONCERNING REQUEST FOR A FIVE-MAN FIRE ERIOADE.
PLANT NAME: RANCHO SECO (SMUD)
REVIEWER INITIAL:
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o**************** DISTRIBUTION OF THIS MATERIAL IS AS FOLLOWS ******************
FIRE PROTECTION INFORMATION (AFTER ISSUANCE OF OL).
(DISTRIBUTION CODE AOO6)
FOR ACTION:
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INTERNAL:
REG FILE **
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NRC PDR**LTR ONLY(1) t a< ONLY(2)
OELD**LTR ONLY(1)
AUXILIARY SYS BR**LTR ONLY(2)
AD FOR SYS & PROJ**LTR ONLY(1)
PLANT SYSTEMS BR**LTR ONLY(5)
WAMBACH**LTR ONLY(1)
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MURANKA**LTR ONLY(1)
HANAUER**LTR ONLY(1)
EXTERNAL:
LPDR'S SACRAMENTO, CA**LTR ONLY(1)
REGION V**LTR ONLY(1)
TIC **LTR ONLY(1)
NSIC**LTR ONLY(1)
ACRS CAT B**LTR ONLYC16) l
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DISTRIDUTION:
LTR 40 ENCL 0 CONTROL NBR:
94d4000594 SIZE: 6P cocoo******************************
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,j SMUD SACRAMENTO MUNICIPAL UTILITY DISTRICT O 6201 S Street, Box 15830, Sacramento, Califomia 95813; (916) 452-3211 June 26, 1978 6D~3/1 Nuclear Regulatory Commission ATTN:
Mr. Victor Stello, Director Division of Operating Reactors Office of Nuclear Reactor Regulation Washington, D. C. 20555 Re:
June 5, 1978 Letter V. Stello Jr. to J. J. Mattimoe
Dear Mr. Stello:
Our previous letter and discussions with your staff have provided our reasons for our concerns, and we would like to reiterate and elaborate our objections to the request for a five-man fire brigade.
The notation that the career fire service considers a minimum manning requirement of five men, one officer and four team members, is erroneous.
The trend in career fire service is now towards Quick Response Units (QRU).
QRU's consisting of three men is not only a budget consideration but nationwide statistics reveal that between 75% and 80% of fire department calls are rescue aid or small fire calls. Economics and common sense dictate that responding a $100,000 truck with a full crew to these types of calls is not reasonable. Our largest area fire department, the Sacramento City Fire Department, with over 500 me.n is already in the process of adopting this strategy and indeed some houses already are manned and respond with three men.
There is no direct correlation between municipal fire fighting and nuclear power plant fire fighting.
A city fire department can anticipate varying degrees of fires of varying magnitudes based on multiple structures of varying degrees of flammability. Our original plant design was developed with enough foresight to prevent the possibility of a major fire occuring.
Our " Fire Hazard Analysis" and report on " Fire Stop Tests for Rancho Seco Nuclear Generating Station" clearly indicate that the postulation of a major fire occurring is very remote. The development of fire causing scenarios has proven to be a difficult task in that the original design requirements restricted use of combustibles and our cabling does not support combustion.
The cabling fire does not propagate; the fire in electrical equipment affected is deenergized; and any remaining class "A" fire is quickly extinguished by j
automatic systens. The fire brigade can only be foreseen as observers of actions that already have occurred with no fire fighting skills needed at all.
Currently, plant modifications to fire detection equipment, fire fighting equipment, and fire barriers all reduce the need for fire fighting capabilities even further than did the original design.
RoSt/g6 AN ELECTRIC SYSTEM S E RVIN G MORE THAN 600,000 IN THE HEART OF C AllF 0 R N I A
s Nuclear Regulatory Commission June 26, 1978 The Design Basis Fire is formulated into considering all combustibles in an area and that no fire supression (manual or automatic) action is taken.
The Reactor Protection and Safety Features Actuation System are required to detect -abnormal reactor or reactor building conditions and initiate automatic reactor shutdown or safety features actuation, and they are not per se required for manually shutting down or cooling down the reactor with loss of of f site power.
Consequently, the position is taken, regardless of the single fire area in which a postulated Design Basis Fire may occur, a safe shutdown can always be accomplished by manually initiating a trip of the reactor.
Present plant design alone would alleviate the necessity for a three man fire brigade.
Current modifications, as extensive as they are, when completed would justify negating the requirement for a three man emergency team within the first 30 minutes.
Your letter dated June 5,1978 included as an attachment a document entitled
" Manpower Requirements for Operating Reactors." That guidance document in essence reiterates a previous staff belief that the minimum fire brigade size of five persons needs to be established. As we have expressed in our previous correspon-dence, we have a serious concern for establishing a minimum brigade size of five Our previous letter and our discussions with your staff have provided our men.
reasons for our concerns, and we would like to reiterate our objections to your position in summary form.
In addition to our technical disagreements with your current position, of equal concern to us is the procedural manner which the staff is using to establish minimum regulatory requirements for all operating reactors.
Based upon our review of the record on fire protection, the only documented reference we can locate which is the apparent basis for recommending a five-man brigade, is an October 19, 1977 letter from Robert E. Hall of the Reactor Engineering Analysis Group of Brookhaven Laboratories to R. L. Ferguson which recommended such a position.
In establishing the minimum fire brigade size of three persons at our facility, we considered the arguments presented in that memorandum and provided our basis for establishing a smaller brigade. Your letter reiterates the same basis for establishing a five-man fire brigade as did your earlier memorandum; and there appears to have been little, if any, recognition of our ' previous comments of December 16, 1977, the Fire Hazards Safety Analysis Report and the two amendments to DPR-54, Nos. 18 and 19 issued on February 14, and 28, respectively.
At the outset, we wish to state that our position remains as before; that is, a three-man fire brigade would be able to cope with fires at our facility.
It is our position.that in response to a fire alarm two members of the fire brigade would respond at the site immediately, with the third member of the brigade allowed to respond at a later time.
j As we have discussed in our prior submittals, the philosophy for protection against fires is that of defense in depth; that is, to prevent the fires, prompt I
Nuclear Regulatory Commission June 26, 1978 detection and extinguishment of any hazard, and provisions to minimize the effects of the fire.
In evaluating the consequences of fires at our facility, the NRC required that we prepare a Fire Hazards Analysis Report.
This report, which was submitted to you on August 1,1977, provided our evaluation of postulated fires in the various fire zones as established within our facility.
As indicated in that analysis, conservative assumptions were made with regard to the fire loading; and the results of that analysis indicated that the design features provided our facility are adequate to cope with the consequences of a fire.
Our report showed that not responding to fires in many areas of our plant would not result in the loss of ability to place the plant in a safe shutdown mode or have an impact on the health and safety of the public.
However, fire detection systems are installed and maintained such that most fires would be detected at their inception and in certain plant areas, automatic systems are actuated to extinguish any fires that are detected.
In other areas, initial reliance may be placed upon the use of manually actuated systems.
It has been the staf f's position that manually operated back-up fire extinguishing equipment (e. g., fire hydrants) be provided for all fire zones having safety related systens. In operating these back-up fire extinguishing systems operator intervention is, of course, required.
It is our view that, r
at most, three persons are needed to effectively operate systens as installed.
As the NRC properly recognizes, the actions of the plant staff in this event are expected to be of short duration, that is, on the order.of thirty minutes.
Should a fire occur, the location of that fire should be identified by the fire detection system.
In our view the proper response of a fire brigsde would be to have two persons enter the area identified and evaluate the situation. Should the fire be of such a nature to require actuation of the back-up fire protecti_n system, up to three individuals could be gainfully employed in these fire fight-ing activities.
These three individuals are provided sufficient equipment, including air supply, to permit them to actively support any fire fighting activities for the desired period of time.
It is generally acknowledged that to operate the installed fire hoses inside a nuclear power plant (1-1/2 inch diameter) two persons in protective equipment can adequately handle and manipulate the needed equipment. Since all the equipment being utilized in the initial phases of fire fighting activity is strategically located, breathing apparatus is available; and we are required to have at least two spare tanks available. We are of the opinion that additional dedicated fire fighting personnel are not required.
As stated above, SMUD has installed considerable automatic fire supervision equipment at Rancho Seco and is performing the testing and training of fire brigade as described in the Technical Specifications.
An evaluation was made of the historical records of fires at nuclear power reactors as reported to the NRC. The major source of information was from the references in NUREG-0050, " Recommendations Related to Browns Ferry Fire".
'The references listed 46 fires which had occurred. There have been 14 additional
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Nuclear Regulatory Commission June 26, 1978 fires reported to the NRC in licensee event reports which have been entered into the computer-based record retrieval system since the Browns Ferry Report.
In addition to reviewing the summaries of these fires as entered, a number of the reports from the licensees were reviewed in the Public Document Room to obtain further information.
As evaluated, of the 60 fires reported, 38 of them occurred directly as the result of construction, maintenance or testing activities, most of the time when the plant was not in operation. There were eight cases identified when the fire occurred during a period of normal operation when no construction, maintenance or testing operations were in progress.
In 14 of the events, the summaries were not complete enough to establish the status of the plant.
In any event, the record clearly establishes that fires are least likely to occur on the routine shifts when the plant is in normal steady state power operation.
The requirement for the five-man fire brigade during this period of minimum activity is not supported by the record of the 60 fires.
The historical record also shows that those fires involving electrical cable or equipment were in most cases promptly extinguished (a notable exception was the Browns Ferry fire).
In fact, many of the electrical equipment fires were extinguished hv removing power from the quipment.
As a consequence of the Browns Fer both the NRC and industry were active in upgrading the requirements i
.apabilities for coping with fires.
The upgraded equipment installed since the Browns Ferry fire, as well as the development of better instructions for combatting fires, reduces the probability of another fire similar to that at Browns Ferry.
One objectionable feature of the proposed technical specifications as distributed by the NRC on fire protection is the interim requirement for a five-man fire brigade. The five-man requirement is indicated to be interim in nature and subject to revision when the detailed plant review is complete.
We are of the opinion that there are not sufficient bases to warrant the imposition of such a requirement, particularly on an interim basis which requires hiring and possibly firing of individuals whose special skills may not allow them to be used for other plant functions.
The NRC position for five members of a fire brigade is contained in a memorandum of November 4,1977, from D. G. Eisenhut to K. Coller and a similar recommendation from Brookhaven National Laboratory dated October 19, 1977.
Those memoranda indicate the NRC position was partially based on precedent.
While it is true that some fire departments use five-man response teams, others use less.
For example, one department that uses a five-man response was asked for their rationale. The stated reason for five men to accompany an engine company is that two trucks are utilized by this five-man crew and additional persons are required to operate this equipment. Another significant factor is that commercial fire companies connect to hydrants having 2-1/2 inch diameter hose fittings, requiring more personnel to handle the hoses than if the 1-1/2 inch hoses installed in our plant were to be used.
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s Nuclear Regulatory Commission June 26, 1978 A call was also placed to the crash crew chief at an Air Force base near Washington, D. C.
The crash crew is the emergency response force in the event of an aircraf t crash at the base. Their response is, of course, to save lives and protect property in the event of a crash at the site.
As described, a crash crew consists of a three-man team who man a special vehicle at the base.
The teams are trained to fight fires as well as to enter smoke-filled aircraft to save lives.
It was indicated that although the concept is to use three-man teams, at present only two-man teams were used at the base contacted.
This is considered the minimum size, mainly for the safety of the team itself.
NFPA Standards were also reviewed to determine if any provided guidance 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 men 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."
There is no indication that a minimum brigade size of five is desired; ra the r, it states size should depend on nature of equipment to be cred. In the initial response to a fire in a nuclear power plant, t'ie only equipment to be used is that disbursed or permanently installed in the plant.
In this instance it is difficult to imagine what five men as stated in the NRC staff memorandum could accomplish that could Mor be accomplished by a two-man brigade receiving instructions from the plant cotitrol room or fire control panel.
As such, we recommend our fire brigade requirements be for esto immediate response personnel augmented as required by cne individual (site s tecific - who may or may not have other duties) to establish continuing commun ' cations.
As discussed in prior submittals, the philosophy for protection against fires is that of defense in depth; that is, prevention of fires, prompt detection and extinguishment of any hazard, and provisior. for minimizing the effects of fires. All of these principles have been applied at our facility.
The use of fire brigades deals with the issue of extingusshment of fires that are not automatically coped with.
In this regard, detection systems are installed ani maintained such that any fire would be detected at its inception.
In certain plent areas automatic sys-tems are actuated to extinguish any fires that are dete( ted.
In other areas, initial reliance may be placed on the use of manually actuated systems.
In addition, it has been recognized that a backup manually-operated water fire extinguishing system could be required.
Persons required to operate this manual water fire extinguishing system set the minimum size of the fire brigade.
Should a fire occur, the location would be identified by the fire detection system. To operate the water hoses would require a minimum of two persons to don protective equipment and enter the area. Since the fire hoses are permanently
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a Nuclear Regulatory Commission June 26, 1978 installed and are of a size (1-1/2" diameter) a single person could handle, the prime reason for two persons to enter the area is for personnel safety.
t In the instance of trained persons entering an environment for which they are familiar and know beforehaad the potential for combustion in the area, there is no need to have a separate " fire supervisor" at the scene to observe and direct their efforts. This is not to say that one individual should not be in charge of the fire fighting efforts, rather, it is to emphasize that when two trained individuals enter an area to fight a fire, their initial efforts I
should be set by their understanding of the potential nature of the fire and their training to respond. After the initial two-man response, it may be desirable to augment the ef forts at the scene by another individual who may be the supervisor or a person who relays information from the scene to the supervisor. Since all equipment being utilized in the initial phases of fire fighting is pre-installed and breathing apparatus requirements are to have at least two spare tanks available, we are of the opinion that additional i
dedicated fire fighting personnel are not required.
Therefore, for the above stated reasons and the implications of the Fire Safety Analysis Report that does not require a fire brigade, the District is willing to provide a defense in-depth by establishing a three-man fire brigade.
I Respectfully submitted, Le J.
. Mattimoe Assistant General Manager l
and Chief Engineer 2
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