ML19326C553
| ML19326C553 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 06/21/1978 |
| From: | David Williams ARKANSAS POWER & LIGHT CO. |
| To: | Stello V Office of Nuclear Reactor Regulation |
| References | |
| 1-068-11, 1-68-11, NUDOCS 8004230670 | |
| Download: ML19326C553 (5) | |
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$h f REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
DISTRIBUTION FOR INCOMING MATERIAL-sO-3 * :68 REC: STELLO V ORG: WILLIAMS D H DOCDATE: 06/21/78 NRC AR PWR & LIGHT DATE PCVD: 06/29/78 DOCTYPE: LETTER NOTARIZED: NO COPIES RECEIVED LTR 4 ENCL 0
SUBJECT:
FURNISHING RESPONSE AND COMMENTS TO NRC LTR DTD 06/05/78, INCLUDING DOCUMENT ENTITLED: " MANPOWER REQUIREMENTS FOR OPERATING REACTORS", RE MINIMUM FIRE DRIGADE SIZE OF FIVE PERSONS NEEDS TO BE ESTABLISHED FOR SUDJECT FACILITY.
PLANT NAME: ARKANSAS - UNIT 1 REVIEWER INITIAL:
XJM ARKANSAS 1 - UNIT 2 DISTRIBUTER INITIAL:
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FIRE PROTECTION INFORMATION (AFTER ISSUANCE OF OL).
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MMOT'E'Ehycgn' ARKANSAS POWER & LIGHT COMPANY POST OFFICE BOX 551 UTTLE ROCK, ARKANSAS 72203 (501)371-4000 June 21, 1978 1-068-11 2-068-25 Director of Nuclear Reactor Regulation ATTN:
Dr. Victor Stello, Jr., Director Operating Reactors 3
U. S. Nuclear Regulatory Commission
~3 Washington, D. C.
20555
Subject:
Arkansas Nuclear One-Unit I f, 2 Fire Brigade Size Docket No. 50-313, 50-368 License No. DPR 51 (File:
1510, 2040, 2-1510, 2-2040)
Gentlemen:
Your letter dated June 5,1978, included as an attachment a document entitled " Manpower Requirements for Operating Reactors."
ance document in essense reiterates a previous staff belief thatThat guid-i minimum fire brigade size of five persons needs to be established.the Since we had previously (May 24) taken exception to this document and scheduled an ap-1etter requested our response in twenty days in the manner that i
l did without acknowledgement of the currently ongoing interactions be-tween us and the staff on this topic.
In addition to the technical disagreements with your current position (which we have previously provided) 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. IIall of the Reactor Engineering Analysis Group of Brookhaven Laboratories to R. L. Ferguson which recommended such a pos'ition.
establishing the minimum fire brigade size of three persons at our In facili ty, we considered the arguments presented in that memorandum and provided our basis for establishing a smaller brigade.
reiterates the same bases for establishing a five-man fire brigade as Your 1ctter did your earlier memorandum and there appears to have been little, if any, recognition of our previous comments.
oV MEMBER MtOOLE SOUTH UTIUTIES SYSTEM
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Dr. Victor Stollo June 21, 1978 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.
In recognition of your desires to have two additional persons to obtain equipment and aid in filling air cylinders, we will agree to designating two individuals to pro-vide this assistance as outlined in our letter of June 13, 1978.
'Ihese two individuals, however, would not receive the extent of training required of the fire brigade members also as outlined in the above letter.
As we have discus sed in our prior submittals, the phi *osophy for protection against fires is that of defense in depth; that is, to preven't the fires, prompt detection and extinguishment of the hazard, and provisions to minimize the effects of the fire.
In evaluating the consequences of fires at our facility, the NRC required that we per-form a fire hazards analysis. The results of this analysis, which was submitted to you on December 20, 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 in our facility are ade-quate to cope with the consequences of a fire. Our analysis showed that not responding to fires in any area of our plant would not result in the loss of ability to ' place the plant in a safe shutdown mode.
Ilowever, fire detection systems are installed and maintained such that many fires would be detected at their inception and in certain plant arms 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 staff's position that manually operated back-up fire extinguishing systems be provided for all fire zones having safety related systems.
In operating these back-up fire extinguishing systems operator intervention is, of course, required.
It is our view that, at most, three persons are needed to effectively operate systems 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.
In our view should a fire occur the pro-per response of a fire brigade 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 protection system, up to three individuals could be gainfully employed in these fire fighting 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 (or longer). Our Fire Team described in the Emergency Plan would be
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Dr. 'Victer Stallo June 21, 1978 available to fight longer duration fires.
It is generally acknowledged that to operate the installed fire hoses at a nuclear power plant (1h inch diameter) two persons in protec-tive equipment can adequately handle and manipulate the needed equip-ment. Since all the equipment being utilized in the initial phases of fire fighting activity is pre-installed, breathing apparatus is available. We are of the opinion that additional dedicated fire fighting personnel are not required.
As indicated in our May 24 meeting and our June 13, 1978, letter, however, we will designate two additional individuals who would be trained to assist the fire brigade although we do not agree with their necessity.
We under-stand that our June 13, 1978, letter resolves this matter.
Very truly yours, q
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Daniel H. Williams Manager, Licensing DI!W:TrE:nh W
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