ML20002C805
| ML20002C805 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 12/15/1977 |
| From: | Bixel D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Desiree Davis Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8101120038 | |
| Download: ML20002C805 (9) | |
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r; s-w Director of Nuclear Reactor Regulation v., 7f r J g2 '
Att: Mr Don K Davis, Acting Branch Chief 7
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Operating Reactors Branch No 2 N,** *
<s US Nuclear Regulatory Cennission Ut f
Washington, DC 20555
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M3,..t DOCKET 50-155 - LICE'!SE DPR BIG ROCK POIUT PLANT - RESPONSE TO PEOPOSED FIRE PROTECTION T/S Ey letter dated November 25, 1977, Censumers Power Ccepany was requested to respend to the proposed Fire Protection Technical Specifications for the Big Rock Point Plant.
After a review of the preposal, Consumers Power Cc=pany concludes that it is in general agreement with the majority cf the iters contained therein; hcVever, there are sc=e specific areas that re-quire additional clarificaticn, rewording or correction.
The remainder of this letter shall address these issues.
I.
Item: Section h.3.3.8.1.b (Page 12-1)
Staff Proposal:
Once per 31 days by verifying proner align =ent of pcVer sources to the nonsupervised circuits.
Rece:mendation:
Once per 31 days by verifying proper alignment of power sources to the circuits.
Discussien:
Eig Rock Point utilizes supervised circuits for their fire detection equipment; however, those presently installed are not UFFA Code 72D, Class A.
II.
Item:
Sectior. 3 7.11.1, Action C.1 (Page 12-3)
Staff Propcsal:
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E::tablish a backup fire supprescica vr. er system within 2h hours and...
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Recommendation:
Initiate procedures to provide a backup fire suppression water system within 2h hours, and...
Discussion:
Because Big Rock Point utilizes the fire suppression water system as the source of water for emergency core cooling system, the loss of a single redundant component necessitates plant shutdown (ref: Technical Specifi-cations Section ll.3.1.4.E).
Thus, if the entire fire suppression system became incperable, the plant would already be in a safe shutdown configura-tion. Since the premise of the Fire Protection Program is to ensure the capability of safely shutting down the plant in case of fire, this criteria
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will have been met at Big Rock Point. To require an additional suppression syste= to be operable within 2h hours does not significantly enhance or alter this capability. Additionally, the standard from which the staff's position is developed, does not require a plant shutdown upon loss of the fire suppression water system if an alternate system can be operational within 2h hours. Clearly, Big Rock Point, by design, is significantly more conservative.
Thus, Consumers Power concludes that since Big Rock Point vould be shut down i==ediately upon loss of a redundant co=ponent of the fire water suppression system, the intent of the staff's position is ade-quately met by initiating procedures to establish a backup system within 2h hours upon inoperability of the entire syste=.
III.
Item:
Section 3.7.11 5, Action (Page 12-6)
Staff Proposal:
1.
With the hose station inoperable, provide an additional hose at the unprotected area from an OPERABLE hose station within one hour, i
Recommendation:
1.
With a hose station inoperable, provide an additional hose for the unprotected area at an OPERABLE hose station within one hour.
4 Discussion:
The recommended change fully meets the intent of the Action specified by the staff's position.
However, it has two specific advantages.
First, by having the additional hose at the operating station, the integrity of the hose vill be maintained since it will remain coiled and not subject to inadvertent damage.
Further, by not laying out the hose from one area to the next, the passage vill remain clear and unobstructed.
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IV.
Item: Section 3.T.12, Action (Page 12-7)
Staff Proposal:
With one or more of the above required penetr tion fire barriers nonfunc-tional, establish a continuous fire watch on at least one side of the affected penetration within one hour.
Recommendation:
With one or more penetration fire barrier nonfunctional, establish within one hour a fire inspection tour of the area on at least one side of the penetration once every hour.
Discussion:
A continuous fire watch for the loss of a penetration fire barrier is extreme and inconsistent. The defense in depth concept to which the Big Rock Point Plant is designed assures that a degradation of a fire penetra-tion barrier will not affect the performance of the installed fire detec-tion and suppression systems, systems that are much more sensitive to discovering combustion than a fire watch. Thus, it is concluded thct the action required for a nonfunctional fire barrier should be comparable to the action required for a nonfunctional detection system - an hourly fire patrol. Additionally, it is anticipated that during major outages, pene-j (
tration barriers will be violated. To have additional personnel in these areas at those times is unnecessary and serves no valid purpose since the plant is already in a safe shutdown condition.
V.
Item: Bases 3/h.T.11, Fire Suppression Systems (Page 12-8)
Recommendation:
Delete "CO, Halon" from Line 5 2
Discussion:
Big Rock Point does not utilize CO2 or Halon as a fire suppression system in safety-related systems.
VI.
Item: Bases 3/h.T.12, Penetration Fire Barriers (Page 12-8)
Staff Proposal:
During periods of time when the barriers are not functional, a continuous fire watch is required to be maintained in the vicinity of the affected barrier until the barrier is restored to functional status.
Recommendation:
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During periods of ti=e when the barriers are not functional, a fire watch patrol is required to tour the affected barrier hourly until the barrier is restored to functional status.
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i Discussion:
This change is recommended to update the Bases as discussed in Item II.
VII.
Item: Section 6.2.2.f (Page 10-1)
Staff Proposal:
A fire brigade of at least five members shall be maintained on site at all times. This excludes two members of the minimum shift crev necessary for safe shutdown of the plant and any personnel required for other es-sential functions during a fire e=ergency.
Reco==endation:
A fire brigade of at least three me=bers shall be maintained on site at all times. This excludes two members of the minimum shift crew necessary for safe shutdown of the plant and any personnel required for other es-sential functions during a fire emergency. Either the SAS or CAS operator may be used as a fire brigade me=ber.
Discussion:
An evaluation by our consultant, KMC, [ne, ris made of the historical * ) cords of fires at nuclear power reactors as reported to the NRC. The major source 4
of information was from the references in NUREG-0050, "Reco==endations Related to Browns Ferry Fire."
The references listed h6 fires which had occurred.
There have been 1h additional fires reported to the NRC in licensee event reports which have been entered into the co=puter based record retrieval system since the Browns Ferry Report.
In addition to reviewing the su=-
maries of these fires as entered, a nudber of the reports from the licensees were reviewed in the Public Document room to obtain further infor=ation.
As evaluated, of the 60 fires reported, over 38 of them occurred directly as the result of construction, maintenance or testing activities occurring when the plant was not in operation. There were eight cases identified when the fire occurred during a period of normal routing operation when no construction, maintenance or tecting operation was in progress.
In lh of the 38 events, the su== aries 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. This is the period of time when there are the fewest persons at the site and the stated requirement for the five-man fire brigade the most onerous.
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 electrieal equipment fires were extinguished by re=oving power from the equipment.
As a consequence of the Browns Ferry Fire, both the NRC and industry were f
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active in upgrading the requirements and capabilities for coping with fires.
The upgraded equipment installed since the Browns Ferry Tire as well as the development of better instructions for ce= bating fires reduce the probability of another fire similar to that at Browns Ferry.
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The five-man fire brigade requirement, as specified above, 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 possible termination of indi-viduals 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 h,1977 from D G Eisenhut to K Goller and a similar recommendation from Brechhaven 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 teams, othel; use less. For example, one department that uses a five-man response was asked for their rationale. The stated reason for five =en to accompany an en-gine company is that two trucks are utilized by this five-man crew and additional persons are required to operate this equipment. Another sig-nificant 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 the 1-1/2-inch hoses used at Big Rock Point.
Our,coniultant also contacted the crash crew chief at an Air Force base near Washington, DC.
The crash crew is the emergency response force in the event of an aircraft crash at the base.
Their response is, of course, j
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 are used.
This s 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 vill 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 com-panies may be composed of two or more men to operate a specific item of equip =ent 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; rather, it states size should depend on n3ture 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 disbursed or permanently installed in the plant.
In this instance, there is virtually nothing that five men, as stated in the NRC staff =emorandu=, could accomplish that could not be accomplished by a two-man brigade receiving instructions from the plant
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control room or fire control panel. As such, Consumers Fever Company concludes that fire brigade requirements for two immediate response
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personnel augmented as required by one individual to establish contin-uing communications be incorporuted in the Technical Specifications:
Further, that the additional individual may be either the SAS or CAS operator for reasons amplified below.
The philosophy for protection against fires is that of defense in depth, that is, prevent fires, prompt detection and extinguishment of any hazard and provisions for minimizing the effects of fires. All of these principles have been applied at Big Rock Point. The use of fire brigades deals with the issue of extinguishment of fires that are not automatically coped with.
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 eny fires that are detected.
In other areas, initial reliance may be placed on the use of manually ac-tuated systems. In addition, it has been recognized that a backup manually operated water fire extinguishing system could be required. Persons re-quired 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 vould require a cdnimum of two persons to don protective equipment and enter the area.
Since the fire hoses are per=anently 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.
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the instance of trained persons entering an environment with which they are familiar and know beforehand the potential for combustion in the area,
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there is no need to have a separate " fire supervisor" at the scene to ob-i serve 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, i'
their initial efforts should be set by their understanding of the potential nature of the fire and their training to respond. After the initial two-l 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 in-fonsation from the scene to the supervisor. Since all equip =ent being utilized in the initial phases of fire fighting is preinstalled and breath-ing apparatus requirements are to have at least two spare tanks available, Consu=ers Power Company concludes that additional dedicated fire fighting personnel are not required.
Additionally, it becomes prudent to discuss the characteristics of the Big Rock Point Plant itself.
It is a small, unique plant that is well laid out and defined. Personnel are thoroughly familiar with system configura-tions and plant arrangement.
The NRC has acknowledged this fact by allowing a shift co=pliment_ of only four people during normal operations as opposed to the standard of five.
If a fire should occur, the response of the two-man fire brigade vould be immediate, and the possibility of fire propagation virtually nonexistent. Additionally, should backup assistance be required, the Charlevoix Fire Department is less than five miles away and could be l
expected to respond rapidly to any call for assistance.
Routine training s
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conducted between the plant staff and the Charlevoix Fire Department ' ensures proper coordination and equipment and procedural familiarity and further exemplifies the necessity of only a three-man fire brigade.
.A t ough five persons are not needed in a fire brigade, there is no re'ason lh why security persons'should arbitrarily be excluded from assisting in any
' fire fighting efforts. The cne objection voiced to this concept is that j '
the fire may be set as a diversionary tactic.
This concept needs critical evaluation since this is the only reason voiced in objection to the use of security force personnel. The security force represents the one group i
~ of additional employees who are continuously available at the site and could assist in some fire fighting tasks or other miscellaneous tasks, l
such as in communications, without detracting from their ability to respond to a security emergency if required. To not use these employees during a l
fire emergency would appear unwarranted. This is particularly true.in-the instance of the CAS-SAS operator combination.
In the instance of a j'
' fire in a vital area, it may be desired to use one of these security op-i erators as a matter of routine. Since neither operator normally enters a i
vital area, but rather remains at a control console, if the fire were a di-f versionary tactic neither of these individuals would have been involved and, hence, neither would need to be considered the " insider." Since all i
SAS-CAS tasks can be handled by either operator, there no longer exists a security' advantage to man both security posts during this specific emergency.
'I In'our assessments there are two basic events, either the fire was set as a diversionary tactic or it was initiated from other causes (includ-ing that it was set by a single insider as the basic sabotage 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 as-sistance and communication activities rather than fire fighting. Spe-cific cases are discussed below.
1.
Fire Set as Diversionary Tactic - In this instance, an " insider" exiits and has set the fire in atte= pts to distract attention from his helpers in gaining access to the site.
If the fire is in a non-I 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 j
is a definite security advantage in having two security persons as-l sisting and observing plant operators (one of which may be the "in-sider").
In this situation, if one security officer and one operator were providing on-call assistance and one security officer was i=medi-ately at the scene handling co==unications while two operators were fighting the fire, the chances of any member of the fire brigade caus-ing further mischief (should one be the " insider") is significantly re-duced. Again, in this scenario if an attack by " helpers" occurred, the security officers may need to abandon their fire fighting efforts to coun-g
.ter the assault and the fire fighting could continue to' be handled by 4
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two designated persons.
In these scenarios, the delayed employ =ent of' security officers would not measurably detract from security efforts and, in our opinion, could tend to deter further actions of an
" insider."
2.
Fire Not a Diversionary Tac +.ic - In this instance, there is no security advantages in not using security officers to assist in fire fighting.
In summary, Consumers Power Company accepts the Fire Protection Technical Speci-fications as provided in the letter of November 25, 1977, except as discussed
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above.
It is Consumers Power Company's understanding that upon resolution of all comments, an amendment to the Big Rock Point operating licensee vill be issued containing the Fire Protection Technical Specifications. Because of the necessity to develop and approve procedures, formalize and complete staff training and obtain any adQtional equipment necessitated by the additional requirements, it is re-quested that the amendment be written to require implementation of the Technical Specifications at least 90 days after issuance.
This vill ensure a systematic and thorough incorporation of all specifications into existing plant procedures and methodology.
David A Bixel Nuclear. Licensing Administrator CC: JGKeppler,'USURC
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n NR C P' ;M 196 U.S. NUCLEAn REGULATCRY COMMiSSI oOCKET NUM BE R 4
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NRC DISTRIBUTION roR PART 50 DOCKET MATERIAL FROM:
oATE op oOCUMENT To:
Consumers Power Company 12/15/77 Mr. Don K. Davis Jackson, Michigan oATE REcEivEo David A. Bixel 12/20/77 E uETTER ONOTOR 2Eo PROP INPUT PORM NUMBER OF CoPtLS RECEIVEo C RiciNAL tsNCLAssimiEo CCOPv ogpopeo oESC%lPTICN ENCLOSU R E Consists of response to proposed Fire Protection Tech Specs for the Big Rock Point Plant.....
PI. ANT NAME:
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Big Rock Point DISTRIBUIION OF FIRE PRUIECTION INFO PER S.SHEPPARD 9-22-76 FOR OPERATING REACTORS RJL 12/20/77
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