ML19319E162

To Proposed Amend 47 to License DPR-54,modifying NRC 771128 Submittal of Interim Tech Specs on Fire Protection

ML19319E162
Person / Time
Site:	Rancho Seco
Issue date:	12/16/1977
From:	Kaplan D, Mattimoe J SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:
References
NUDOCS 8003310681
Download: ML19319E162 (10)

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GNU EST0'ly 00dET FI'2E COPY SACRAMENTO MUNIC; PAL UTittTY D;3TRICT C C201 S Street. Cox 15330. Sacramento Cc'ifornia 05213; (016) 452 2211 OO Decemb'er 16, 1977 g

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Director of t!uclear Reactor Regulction ll M

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Karl R. Go'ller S'y

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Division of Operating Reactors gi U. S. Nuclear Regulatory Cornission 5',

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Docket flo. 50-312 Proposed Amendment No. 47. P,ev. 2 Rancho Seco Nuclear Generating Station, Unit No. 1 Gentlemen:

By letters dated Septerter 30, Deccmber 2, 1976, and June 16, 1977, to Mr. J. J. M::tticoc, you requested that Rancho Seco Nuclear Generating Station Unit I submit an interim Technical Spccification on fire protection.

This request was complied with by the District's submittal of proposed Technical Specificatien Amendment flo. 47 on '

st i, 1977 On' November 28, 1977. we received i.cm you the Amendment with several revisions compiled during your staf f review and we have thoroughly revicwed the revised addition for consistencies, practical applications, terminologies and the ability to properly interpret the specific requirements.

Many of the changes have been discussed between tir. L. Olshan (NRC) and Mr. R. Colo nbo (SMUD) on December 7, 1977 The following changes have been made from your November 28 interim Technical Specification submittal to us:

Syecification 3.14.2 d The r.unber of separcte water supplies has been changed from "three" to "two".

Reason:

Althcugh Rancle 5cco has the ability to provide three separate sources to the fire suppression systcm, operational flexibility shculd be provided to require only tuo.

TFc plant fire protection system Jill not be comp omised b/ removal of any cne of tbc three syste s for indeterminate perieds of time.

Two ec:ct sources will previde' sufficient redundar.cy for fi re pro-tection water supolics.

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v.s. NucLaAR REGULATORY Comb 4SloN ooCKET NUMsE R NRC romu 195

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oATE CP oCCUMENT TO:

Sacramento Municipal Utility Dist 12/16/77 Sacramento, California e4Te naCaiveo Mr. Karl R. Go11er 1/04/77 J. J. Mattimoe Es-rs e CNoToar:so race iNeuT pomu NuussR ce Copies asCsivso ComiclNAL MUNCLASSIFIE o

/E X Cav ENCLoSU RE CESC0teTsoN Notorized 12/16/77...trans the following:

ficense No. DPR-54 Appl for Amend: tech specs proposed change concerning fire protection at Rancho Seco....

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December 16, 1977

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- Specification 3.14.2.3c

' The' time'to submit a Special Report is ten (10) " working" days.

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Reason:

If a report is caused by a situation occurring on a long weekend (h'oliday"T, the actuai ' reply time is five (5) days which. is too short

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to provide a comprehensive' report and evaluation.. Ten.(iO) " working" days

' will-allow sufficient review and evaluation to provide a meaningful report,to

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. the; Commission.

Speci ficat ion L 3.14.2 3d'

. The. time to go to the Hot Standby condition has been changed to

' four (4) hours.-

Reason: A shutdown initiated. hy not providing. the. i tem "a" backup does r.ot-constitute an. emergency and to prevent;further problems, the shutdown should be performed.according to normal operating procedures.

The procedure considering all operating limits and no immediate emergency requires approxi-lrnately four (4) hours to go from full power to hot standby.

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Specification 3.14~.5.le ga1

- The chordinctes' are. "!!59+17; E324 20".

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Reason:

Specification _3.14.5.2

.The word "capac'ity" has' been changed to " size".

Reason: An' equivalent capacity hose is indeterminate. An equivalent

" size" hose -is a specification-that can be obtained, audited against and complied with as~ a ' specification.

Specification 4.18.1.1:

- " Sect ion. 3.14.3 1" should be changed to ' Table 3.14-1".

Reason: This will prevent identical testing as could be interpreted in old Specification 4.18.1 3 Specification 4.18.1.1 Remove r the word "FU!!CTIONAL" from the specification.

Reason: ThereLis no ' definition for a " Channel Functional Test" but there is a definition Lfor a'"Chhnnel. Tcst" which is applicable to this specifi-

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December 16, 1977 Specification 4.18.1.2_

Add words " Fire detection" and remove "a and b".

Change "each refueling" to "during cach refueling interval".

Reason: To clarify the type of instrumentation to be demonstrated operable and to delete the "a and b" specification changed to a sinole specification by HRC. The time period was changed to permit operational flexibility.

Specification 4.18.1.3 Add words " sprinkler water flow", "in Section 3.14.3.1" and change "once every six (6) nonths for all NFPA Code 72D Class A circuits" to " semi-annually".

Reason: To clarify the type of instrumentation to be demonstrated operable, agree with Technical Specification definitions and to delete a type of circuit that does not exist at Rancho Seco.

Specification 4.18.2.f Reverse words " Chapter 5, Section 11" to "Section 11, Chapter 5".

Reason:

Clarification.

Specification 4.18.2 9 Add'words "as indicated by position instrumentation".

Reason:

To clarify how the position verification will be performed.

Specification 4.18.2.i.3 Change word " cycle" to " interval".

Reason:

To' agree with Technical Specification Definitions.

Specification 4.18.2.i.3.a Delete words " cell plates".

Reason: The batteries are cast bakelite and are not transparent.

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December 16, 1977

. Specification 4.18.3

• e Add."sp'ecified in Section 3.14.3.1".

Reason:- Clarification.

. Specification 4.18.3.b.2 Add "and/or sprinkler".

Reason: _ Consistency Specification'4.18.3.b.4 Delete Reason: The specification applies to dry pipe system as delineated in the NFPA Codes and Standards Volume One, Standard 13, Chapter 1-11.4 ' Tests of Dry Pipe Systems". There are no dry pipe' systems at Rancho Seco protecting nuclear safety equipment. All safety-related equipment is protected by wet sprinklers.

Specification 4.18.5.b Remove words "by removing the hose for inspection and re-racking and replacing" and replace with "insp'ect and replace".

Reason:

As stated in Specification 4.18.5d,below,the hose will be replaced every three years and a hose inspection is not required.

Specification 4.I8.5.c

' Add word " valve".

Reason:

Clarification

- Specification 4.18.5.d-Remove phrase from "co,nducting" to the end of the sentence and. replace i

'with " removing-and replacing all hose'with equi. valent NFPA approved 1

hose".

- Reason:

Deterioration-of fire hose is caused by aging, and a total replacenentjof -all fire: hoses. that protect safet'y-related equipment with new hose is a more meaningful specification.

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December 16, 1977

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' Specification 6.2.'2f

• f Change."5" to "3".

Reason:.SMUD has joined the group of utilities represented by KMC inc.

The number of members required for the fire brigade should be resolved as a 9eneric. issue with the considerations, as applied-to Rancho Seco,being very favorable. As stated above, SMUD has installed considerable automatic fire supervision' equipment at Rancho Seco and is performing the testing and training of the'f,Irc 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 ilRC.

The major source of information was from the references in NUREG-0050, "Recomendations Related to Browns Ferry Fir;".

The references listed 46. fires which had occurred.

There have been 14 additional 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,over 38 of them occurred directly as the result of construction, maintenance or testing activities, most of the the tirae.when the plant was not in operatiori.

There were eight cases identified when the fire occurred during a period of normal operation when no construction, maintenanc'c or testing operations were in progress.

In 14'of.the

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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 l

operation.

This is the. period of time when there are the fewest persons at the l

site and the stated requirement for the five-man fire brigade is the most onerous.

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The historical record also shows that those fires involving electrical cable or equipment were in most cases promptly extinguished (a notable exception

. as the'-Browns Ferry fire),

in fact, many of the electrical equipment fires w

l were extinguished by removing power from the equipment.

As a consequence of

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the Browns-Ferry fire both the NRC and industry were active in upgrading the L

. requirements and capabilities for coping with fires.

The upgraded equipment l

Installed since.the Browns Ferry fire as well as the development of better instructions 'for combatting fires reduce.the probability of another fire similar to that at Browns Ferry, Requirement for Five-Man Fire Bricade One objectionable: feature of. the proposed technical specification as R

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~compi cVem r f

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Ecccmber 16, 1977 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 possible 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 memor'anda 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

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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.

A call was also place'd to the crash crew chief at an Air Force base near Washington, D. C.

The crash crcw is the emergency response force in the event of an aircraft 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 wel1 as to enter smoke-filled aircraft to save lives.

It was, indicated that although the concept is to use three-man teams,-at pr This is considered the,esent only two-man teams were used at the base contacted.

4 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 compa'ny 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 tren to operate a specific item of equipment or a larger group to perform more compil-cated operations.

Each company should have a leader and each brigade should have..a chief."

~ :There is no indicatiori that a minimum brigade size of five,is desired; rather it states' size should depend on nature of equipment to be used.

In the initial response to a fire in. a nuclear power plant, the only equipment to be used'is'that disburned'or' permanently' installed in the plant, in this instance itLis difficult to, imagine what five men as etated in the NRC staff memorandum 2 could accomplish that coluld not be accomplished by a two-man brigade receivir.g instructions f rom the plant control room or fire control panel.

As such, we

_ recommend our. fire brigade requirements be for two immediate response personnel augmented as required b'y oncLindividual (site specific - who may or.may not have other.'uties) to establish continuing communications.

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december 16, 1977 Plant Fire ~ Fighting Features Relevant to Size of Fire Brigade As discussed in prior submittals, the philosophy'for protection against fires is that of defense in depth; that is, prevention of fires, prompt detec-tion and extinguishment of any hazard, and provision for minimizing the effects of fires. All of these principles have been applied at our facility. The use of fire brigades deals with the issuc of extinguishment of fires that are not automatically coped with.

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in this regard, detection systems are Installed and maintained such that any fire'would be detected at its inception, in certain plant areas automatic systems are actuated to extinguish any fires that are detected.

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,ermanently installed and are of a size (1-1/2" diameter) a single person cou.d handle, the prime reason for two persons to enter the area is for personnel safety.

In the instance of trained persons entering an environment for which they are familiar and know beforehana the potential for combustion in the area, there is not need to have a separate " fire supervisor" at the scene to observe and direct their ef forts.

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 ef forts 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 efforts at the scene by another individual who may be the supervisor or a person who relays information form 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 dedicated fire fighting personnel are not required.

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Usc~ of Securi ty Forces Personnel in Fire Emergency in our assessments there are two basic events.

Either the fire was set as a diversionary tactic or it was initiated from other causes (including being set by a single-insider as the basic sabatage event).

In either event, the employment of security force personnel as described below is assumed to be-supportive of fire fighting; that is,' on call assistance connunication activities rather than fire fighting.

Specific cases are discussed below.

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D:cembtr 16, 1977 1.

Fire set as diversionary tactic:

In this instance an " insider" exists and has set ene fire in attenpts -to distract-attention from his helpers in gaining access to the site.

If the fire is in a non-vital area, there is lesser. concern 'for_ the consequence of the fire.

In this event, however, assigning security officers to respond could be of some assistance and the security persons could be permitted to leave the scene of the fire if the next act occurs and the " helpers" attempt forceful-entry.

If the fire is set in a vital area, there is a definite security advantage in having two security Lpersons assisting and' observing operators (one of which may be the insider).

In this_ situation, ~ if one security officer and one operator were providing on-call assistance and one security of ficer was immediately at the scene handling communications while two operators were fighting the fire, this vould reduce the-chances of any member of the fire brigade causing further mischief should one be the " insider"..Again in this scenario, if an attack by " helpers" occurred,.the security _ officers may need to abandon their fire fighting efforts to counter thel assault and the fire fighting could continue to be handled by two or three designated persons.

In these scenarios that delayed employment of security-officers would not measurably. detract from security efforts and in our _ opinion could tend to de'ter further actions of an " insider'.'.

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Fire not a diversionary tactic:

In this instance there is no security advantages in not using security of ficers.to assist in fire fighting.

Site Ocoendent Consid! rations 1.

Recall System:

One concept that could be of some.value in the event of a plant emergency would be to maintain a plant recall system.

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l concept,~ persons located in close proximity to the site could be identified and:a procedure written to selectively call back those individuals whose assistance may be required. Although there would be little reason to change personnel' actively fighting the fire in the initial stages, a call back system could make additional plant teams available should fatigue or unanticipated factors arise.

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Response of local.fi re departments:

Although site depen' dent, the capabilities of.the local fire departments should be discussed.

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December 16, 1977.

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Figure 6.2-1

.The -double asterisks have' been added to the "AGM-Chief Engineer".

_ Reason:. C la ri fica t ion.

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. Spec i fica t ior. = 6. 4.2

.Added words "except refresher classroom training shall be on a quarterly schedule."

Reason:

The t;RC ' letter on August 4,1977, to Mr. Ma ctirnoe requires quarterly classroom retraining of the fire brigade.

This specification is in-agreement with the NRC guide requirements.

Respectfully submitted, SACRAMENTO MUNICIPAL UTILITY DISTRICT By hvici. c)

S 'ne el b TITA i

4 J. J. Mattimce Assistant Ger'eral Manager and Chief Engineer

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he o,nd 5lwl b O S g A DAVID S. KAPLAtl J J

General. Counsel'for.

SACRAMENTO MUNICIPAL UTILITY DISTRICT Subscribed and sworn to before rne this

/ 6 ' day of December, - 1977 0V. c t.wh

^$lnne) h.< S (d '.w BETTYJ MATTI ER,- footary Put1 ic in and - tTr

.the County of-Sacramento,

. State of California My Commi ssion Expi.res. Janua ry - l'2, 1980-

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