ML20002C528
| ML20002C528 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point, Palisades File:Consumers Energy icon.png |
| Issue date: | 06/29/1978 |
| From: | Skibitsky W CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Ziemann D Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8101100418 | |
| Download: ML20002C528 (4) | |
Text
-
.a
.a
\\
^
c0nsumers RNdp l P0YlCr a'
C0mpBuy a.n.,. ome..: m2 w..
u cn.a n av.nwea.cm.on, u cmo.n 4o2oi. Ar.. coo. si7 7es.osso June 29, 1978 4'
Director, Nuclear Reactor Regulation Att: Mr Dennis L Ziemann, Chief Operating Reactors Branch No 2 US Nuclear Regulatory Commission Washington, DC 20555 DOCKETS 50-155 AND 50-255 - LICENSES DPR-6
]
AND DPR BIG ROCK POINT AND PALISADES PLANTS -
RESPONSE TO NRC POSITION ON FIVE-MAN FIRE BRIGADE isy letters dated June 8, 1978, Consumers Power Company was requested to respond to the NRC staff position concerning fire brigade manning.
Included as an attachment to those letters was a document entitled " Manpower
(
Requirements for Operating Reactors." This guidance document in essence reiterates a previous staf f belief that a minimum fire brigade size of five persons needs to be. established. As expressed in previous correspondence, Consumers Power Company has a serious concern for establishing a minimum fire brigade of five members. Our previous letters dated December 15, 1977 for both the Big Rock Point and Palisades Plants and our discussions with your staff have specified these concerns. However, in addition to our technical disagreements with your current position, of equal concern is the procedural manner that 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 recommending a five-man brigade is an Octoter 19, 1977 letter from Robert E Hall of the Reactor Engineering Analysis Group of Brookhaven Laboratories to R L Ferguson.
It appears that this is the sole basis for the staff position.
In establishing the minimum fire brigade size of three persons at Big Rock and Palisades, we considered the arguments presented in that memorandum and provided our basis for establishing a smaller brigade.
Your letter reiterates the same bases for establishing a five-man fire brigade as did the '.arlier memorandum; there appears to have been little, it any, recognition of our previously docketed comments, and certainly no comments refuting them.
At the outset we wish to state that our position remains as before; that is, a three-man fire brigade would be able to adequately cope with postulated fires
(
at both the Big Rock Point and Palisades Plaats.
Basically, i3 is our position that in response to a fire alarm, two members of the fire brigade b
'O O D b.vM-810116C915
@0
4' i
2
(.
would go to the fire area immdiately, with the third member of the brigade allowed to respond at a later time. This would adequately provide the necessary response to control any postulated fire until supplemental or. backup assistance'were provided if necessary.
As we have discussed in our prior submittals, the philosophy for protection against fires is that of defense in depth; that is: To prevent fires, to promptly detect and extinguish any hazard, and to provide for the minimization of the effects of the fire.
In evaluating the consequences of fires at our facilities, the NRC required that we prepare a fire hazards analysis report.
.These report.s, which were submitted on March 29 and March 31, 19/7 for the Big Rock Point and Palisades Plants, respectively, provided our evaluation of postulated fires in the various fire zones as established within these
' facilities. As indicated in those analyses, extremely conservative assumptions were made with regard to the fire loading and the extent of the
" Design Basis Fire." The results of the analyses indicated that the design features provided our facilities are adequate to cope with the consequences of a fire. Our reports showed that not responding to the design basis fires in many area: af the plants would not result in the loss of ability to aenieve a safe shutdown condition or have an impact on the health and safety of the public. Further, fire detection and/or suppression systems are installed (or committed to) and maintained such that the ability of design basis fires to develop is virtually nonexistent.
It has been the staff's position that manually operated backup fire I
extinguishing equipment (eg, fire hydrants) be provided for all fire zones
~
having s fety-related systems.
In operating these backup fire extinguishing systems, operator intervention is, of course, required.
It is our view that, at most, three. persons are needed to effectively operate manual 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 30 minutes. Should a fire occur, the location of that fire should be icentified by the fire detection system. As such, the proper 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 backup fire protection system, up to three individuals could be gainfully employed in these fire fighting activities. These three indivi6uals 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).
It is generally acknowledged that the installed fire hoses inside a nuclear power plant (1-1/2-inch diameter) can be adequately handled and manipulated by one or two persons. Since all the equipment being utilized in the initial phases of fire fighting activity is strategically located and breathing apparatus is available, we conclude that aJditional dedicated fire fighting personnel are not required.
The staff position concerning fire brigade manning levels stresses the importance of plant size and geometry in determining brigade size.
During the
(
recent Palisades site visit conducted by your staff, there was go indication that plant specific features were ;onsidered in developing the staff position i
9
{
-t 3
'(
requiring five-man fire brigade. The NRC' staff and their consultant reiterated the standard position without rention of site-specific factors that influenced their decision. Further, there~was little indication that Consumers Power Company's position as specified on the Palisades docket had been evaluated or even considered in the staff's determination. This aspect is also evident in the staff's approach to Big Rock Point. Amendment No 12 to the Big Rock Point Technical Specifications dsted March 16, 1977 reduced the minimum required shift compliment during power operations to four personnel versus the guideline requirements of five. This change was derived in part from the staff's realization that.a small plant like Big Rock Point cannot.
always be generically categorized by standards designed for much larger plants, and that lowering the minimum personnel requirements for such a plant in no way jeopardizes operational safety. One year later the same type of generic guideline concerning personnel application is applied to Big Rock with apparently no regard to previous determinations. The inconsistancies in the staff position are evident.
Thus, in conclusion, Consumers Power Company does not recognize any.
substantial changes in the NRC staff position that would cause alteration of our belief that a three-man fire brigade is adequate to deal with any postulated hazard.
(
M 1)
,N illiam S Skibitsky b
Senior Licensing Engineer CC: JGKeppler, UShTC 1
1 t
zJ hY 4
u REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS
~
- . DISTRIBUTION FOR INCOMING MATERIAL JO
"_e255 REC: 71EMANN D L ORG: SKIBITSKY W S DOCDATE: 06/29/7S NRC CONSUMERS PWR DATE RCVD: 07/03/78 DOCTYPE: LETTER NOTARIZED: NO COPIES RECEIVED
SUBJECT:
LTR 1 ENCL 0 FURNISHING OOMMENTS AND DISCUSSION IN RESPONSE TO NRC LTR DTD 06/08/78 CONCERNING FIRE BRIGADE MANNING. WHICH INCLUDED DOCUMENT ENTITLED: " MANPOWER REQUIREMENTS FOR OPERATING REACTORS". ADVISING THAT APPLICANT DELIEVES A THREE MAN FIRE BRIGADE IS ADEQUATE PLANT NAME: BIG ROCK PT REVIEWER INITI AL:
XJM PALISADES DISTRIBUTER INITIAL:
oc'cGe************ DISTRIBUTION OF THIS MATERIAL IS AS FOLLOWS ******************
FIRE PROTECTION INFORMATION (AFTER ISSUANCE OF OL).
(DISTRIBUTION CODE AOO6)
FOR ACTION:
CR """ r ORBH2 BCu LTR ONLY(4)
^
1 INTERNAL REG F
-LTR ONLY( 1 )
NRC PDR**LTR ONtY(1)
- LTR ONLY(2)
OELD**LTR ONLY(1)
AUXILIARY SYS BR**LTR ONLY(2)
AD FOR SYS t< PROJ**LTR ONLY(1) j PLANT SYSTEMS BR**LTR ONLY(5)
WAMBACH**LTR ONLY(1)
R.
MURANKA**LTR ONLY(1)
HANAUER**LTR ONLY(1)
EXTERNf)L:
LPDR'S (M CHARLEVOIX. MI**LTR ONLY(1)
KAL AM A700 Ltf.
TIC **LTR ONLY(1)
NSIC**LTR ONLY(1)
ACRS CAT B**LTR ONLY(16)
\\\\h
\\G J
DISTRIEUTION:
LTR 39 ENCL 0
- ONTROL NBR-m " o14 SIZE
- 3P
- noo*******************************
THE END
- bilazolnan P00R ORIG Na.
I VJ C L F AR R FCin ATORY COMMISSION
- 9 PAGE :
905
- MASTER RO5TER ***
t 0**
PUBLICATIONS
'00 g
y VISION I
DIS TR IBUT ION Ci 1E S 1-17 -- - --- - ~ l IL E I
D I S T R I B U T I O N
( Y 1 ----
1 TY ST.. ZIP I
D IS T R I BU T ION COUE S 18 - 3 4 -- ----- - (
IPT TYPt i -- r ---- U I ST R I BUT 10N~ QTY 18
~~3 4 ---- ---- T ' ^
l ---------- D I S TR I B U T I O N C OD E S 3 5 - 5 0 -- '
I I
- ty s * * * * * * * * * * * * * * * * * * *
- D I S T R I B U T I O N*************************0-------!
QTY 35 - 5 0 0 0 CO O * * * * * * * *
- t,
1 1
1 1
1 1
1 1
1 J1SVILLE KY 40207 t
st sP SD
~~
~
- - ~
JISVILLE KY 40208 4
JISVILLE KY 40214
'IONRL CRIME PREVENTION INST SM IRARIAN 1
JI SVI LE'c KY 4DZ27 CW JISVILLE KY 40222
]NFORDECARCHHARDWARt SM{si
.HORAGE KY 40223 CW IISVILLE KY 40223
.L T H SCIENCE C ENT ER SN SR SF SE SM SP ST SO SG CW 1
1 1
iSVILLt KY 40232
- - ~ ' - - '
1 1
1 1
1 1
1
~
PROTECT IVE P ACKAGING INC SN SR SF SE SM SP ST SO SA SG 6
1 1
1 1
1 1
1 1
1 1
_I S V I L L E KY 40299 ES E7 ARKETING CW RF3P 5 T S0 5A SG
~~'
E PRESIDENT 1
1 1
1 1
1 1
ISVILLE KY 40299 T OF HLTH R ADI AT ION SCNCE S SN SR SF SE SP ST SG SG
[
INGTO I
Y.
.,