ML20031C369

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Safety Evaluation Supporting Amend 17 to License DPR-6
ML20031C369
Person / Time
Site: Big Rock Point File:Consumers Energy icon.png
Issue date: 03/06/1978
From:
Office of Nuclear Reactor Regulation
To:
Shared Package
ML20031C356 List:
References
NUDOCS 8110070091
Download: ML20031C369 (8)


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....i SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTCR REGULATION SUPPORTING AMENDMENT NO.

TO LICENSE NO. DPR-6 CONSUMERS POWER COMPANY BIG ROCK POINT UNIT NO.1 DOCKET NO. 50-155 INTRODUCTION Following a fire at the Browns Ferry Nuclear Station in March 1975, we initia,ted an evaluation of the need for improving the fire protectinn programs at iil ' licensed nuclear power plants. As part of this continu-ing evaluation, in February 1976 we published a repnrt entitled "Recoamendations Related to Browns Ferry Fire", NUREG-0050.

This report recommer.ded that improvements in the areas of fire prevention and fire control be made in nost exist.ing facilities and that consideration be given to design features that would increase the ability of nuclear facilities to withstand fires without the loss of important functions.

To implement the report's recommendations, the NRC initiated c program for reevaluation of the fire protection programs at all licensed nuclear power stations and for a comprehensive review of all new license applications.

We have issued new guidelines for fire protection programs in nuclear power plants. These guivelines reflect the reconnendations in NUREG-0050.

I These guidelines are contained in the following documents:

" Standard Review Plar, for the P.eview of Safety Analysis Reports for Nuclear Power Plants," NUREG-75/087, Section 9.5.1, " Fire Protection," Nay 1976, which includes " Guidelines for Fire Protection for Nuclear Power Plants," (BTP APCSB 9.5-1), May 1,1976.

" Guidelines for Fire Protection for Nuclear Power Plants"(Appendix A to BTP APCSB 9.5-1), August 23, 1976.

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"Supplenentary Guidance er.?.sormation Needed for Fire Protection Program Evaluation," Sept.ioer 30, 1976.

" Nuclear Plant Fire Protection Functional Responsibilities, A'dministrative Controls and Orality Assurance," June 14, 1977.

8110070091 780306" PDR ADOCK 05000155 P

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. Consumers Power Company (licensee) has sutnitted a description of the fire protection program for the Big Rock Point Unit No.1 by letter dated March 29, 1977, This program is under detailed review by the NRC.

In the interim, until we complete our detailed review, we have co cluded that it is appropriate to amend the facility license by incorporating into the Technical Specifications operability and surveillance requirements for the existing fire protection equip-ment and systras.

In addition, the amendment would include administra-rive requirements for the implementation of the fire protection program.

By letter dated September 30, 1976, we requested the licensee to submit Technical Specifications for the presently-installed fire protection equipment at this facility, By letters of December 2 and 10, 1976, we issued sample Technical Specifications and reiterated that these specifications were for existing systems only.

Subsequently, the licensee proposed Technical Specifications by letter dated March 29, 1977.

Based on our review and consideration of that response and the responses of other licensees, we modified certain action statements and surveillance frequencies in order to provide more appropriate and consistent specifications which we forwarded to the licensee by letter of June 24, 1977.

That letter also requested sutnittal of appropriately revised sr,ecifications.

The licensee responded by letti:.- dated October 28, 1977, We have reviewed the licensee's response and have made modifications where necessary to assure conformance to the fullest extent practicable with our requirements as set forth in the sample Technical Specifications pending completion of our ongoing detailed review of fire protection at this facility.

3 DISCUSSION AHD EVALUATION.

The guidelines for technical specifications that we developed and sent to all licensees are based on assuring that the fire prctestion equip-acat currently installed for the protection of safety related areas of the plant is operable. This assurance is obtained by requiring periodic surveillance of the equipment and by requiring certain corrective actions to be taken if the limiting conditions for operation cannot be met.

These guidelines also include administrative features for the overall fire protection program such as interim fire brigade requirements, training, procedures, management review ano eriodic independent fire protection and loss prevention program inspections.

The equipment and components currently existing at this facility i7cluded in the scope of these Technical Specification requirements are fire detectors, the fire suppression systems, the hose stations, and piping and r.abling penetration fire barriers. Operability of the fire detection instrumentation provides warning capability for the prompt detection of fires, to reduce the potential for damage to safety related equipment by allowing rapid response of fire suppression eouif.r.ent. In the event that the minimum coverage of fire detectors cannot he met, hourly fire patrols are required in the affected area until the inoperable instrumentation is restored to operability. The operability of the fire suppression system provides capability to confine and extinguish fires.

In the event that portions of the fire suppression system are inoperable, alternate backup fire fighting equipment is required to be nade available in the affected areas until the inoperable equipment is returned to service.

In the event that the fire suppression water system becomes inoperable, a backup fire protection water system is required within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and a report to the NRC is required within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to provide for prompt evaluation of the acceptability of the corrective measures for adequate fire suppression capability. The functional integrity of the penetration fire barriers provides protect on to confine or retard fires from spreading to adjacent portions of the f acili ty.

During periods of time when a fire barrier is not functional, a continuous fire watch is required to be maintained in the vicinity of the affected barrier to provide fire prevention methods and prompt detection and suppression in the event of a fire.

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. Ue have reviewed the licensee's propo'.ed interim lechnical Specifi-tations against our requirements as implemented in the sample Technical Specifications. He have made some modifications to the specifications that were proposed by the licensee in order to make them conform to nur requirements. One of the proposed specifications that we changed involves the minimum size of the on-site fire brigade.

In our previous sample Technical Specifications we did not identify the number of members on a fire brigade that we would find acceptable. We have now concluded that minimum number for a typical commercial nuclear power plant to be five (5).

The basis for this conclusion is 9-1sented in an attachment to this Fire Brigade Shif t Size."

SER entitled " Staff Position Mir.: s:

In the report of the Special Review roup on the Browns Ferry Fire (NUREG-0050) dated February 1976, c idcration of the safety of operation of all operating nuclear p plants pending the completion of our detailed fire prot ion evaluation was presented.

The following cuotations from the ren summarize the basis for our conclusion that the operation of the,

.nts, until we complete our review, does not present an undue risk to the health and safety of the public.

"A probability assessment of public safety or risk in quantitative terms.s given in the Reactor Safety Study (WASH-1400). As the result of the calculation based on the Browns Ferry fire, the study concludes that the potential for a significant release of radioactivity from such a fire is about 20% of that calculated from all other causes analyzed.

This indicates that predicted potential accident risks from all causes were not greatly affected by consideration of the Browns Ferry fire.

This is one of the reasons that urgent action in regard to reducing risks due to potential fires is not required.

The study (WASH-1400) also points out that 'rather straight-forward mr:asures, such as may already exist at other nuclear plants, can significantly reduce the likelihood of a potential core melt accident that might result from a largr; fi re. '

The Review Group agrees.

. " Fires occur rather frequently; however, fires involving equipment unavailability comparable to the Browns F The Review Group believes that steps already taken since March 1975 (see Section 3.3.2) have reduced this frequency signi ficantly.

" Based on its review of the events transpiring before, during and after the Browns Ferry fire, the Review Grcup rencludes that the probability of disruptive fires of the magnitude of the Browns Ferry event is small, and that there is no need to restrict operation of nuclear However, it is clear power plants for public safety.that much can and should be don the likelihood of disabling fires and to improve assuranceConsideration of rapid extinguishment of fires that occur.

should be given also to features that would increasef large fires without loss of important functions should such fires occur."

Subsequent to the Browns Ferry fire and prior to the Special Review k

Group's investigation, the Of fice of Inspection and Enforcement too Special bulletins were sent steps with regard to fire protection.

75, and to all licensees of operating power reactors on March 24,19 fire April 3,1975, directing the imposition of certain controls over ignition sources, a review of procedures for controlling maintena and modifications that might affect fire safety, a review of emergenc i

procedures for' alternate shutdown and cooling methods, and a r l

of flammability of materials used in floor and l

cables and in penetration seals were completed at all operating pow flected reactors in April and May 1975. Inspection findings which re l

i ctive non-compliance with NRC requirements resulted in requir n i

are taking the required corrective actions and that administrat ve action by licensees.

control procedures are in place.

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. Since these inspection activities and the subsequent Special Review Group recommendations in the 1975 to 1976 time period, there has been no new information to alter the conclusions of the Special Review Group, and the ongoing fire protection program flowing from those conclusions is still adequate.

Therefore, we have found these specifications acceptable on an interim basis until such time that our overall review is complete, required equipment is installed and operable, and final specifications have been developed and issued.

ENVIRONMENTAL CONSIDERATION We have determined that the planned amendment does not authorize a change in effluent types or total amounts nor an increase in power level and will not result in any significant environmental impact.

Having made this determination, we have further concluded that the amendment involves an action which is insignificant f rom the standpoint of environmental impact and pursuant to 10 CFR 551.5(d)(4) that an environmental impact statement or negative declaration and environ-mental impact appraisal need not be prepared in connection with the issuance of this planned amendment.

CONCLUSION We have concluded, based on the considerations discussed above, that:

(1) because the amendment does not involve a significant increase in the probability or consequences of accidents previously considered and does not involve a significant decrease in a safety margin, the amendment does not involve a significant hazards consideration, (2) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, and (3) such activities will be conducted in compliance with the Commission's regulations and the issuance of this planned amendment will not be inimical to the common defense and security or to the health and safety of the public.

Attachnent: Staff Position - Minimum Fire Brigade Shift Size 1

Date:

November 25, 1977

Attachnent

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Staff Position Minimum _ F,ir,e Grigade Shift Size INTRODl!CTION Nuclear power plants depend en _ the response of an onsite fire brigade fer d.fense against the effects of fire on plant safe shutdown capabilities.

In scme areas, actions by the fire brigade are the

,only means of fire suppression.

In other areas that are protected by correctly designed cutenatic detection and suppression systems, manu.1 fire fighting' efforts are used to extinguish:

(1) ' fires too small to actuate the auto:natic system;- (2) well developed fires if the-autt.natic system-fails to functinn; and (3) fires that are not completelv controlled by the automatic.ystem.

Thus, an adequate fire brigade is essential to fulfill the defense in depth requirements which protect safe shutdown systems from the effects of fires and their related combustion by-products.

DISCUSSION There are a number of factors that should be considered in establishing the minir.:um firc brigcde shif t size.

They include:

1) plant pecmetry and size:
2) quantity and quality of detection and suppression systems;
3) fire fighting strategics for postulateo fires;
4) fire brigace training;
5) fire brigade eouipment; and
6) fire bripcde supplements by plant personnel and local fire department (s).

In all plants, the majority of postulated fires are in enclosed window-less structures.

In such areas, the working environment of the brigade created by the haat and smcke buildco within the enclosure, will requir e

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the use of self-contained breathing apoaratus, smoke ventilation equipment, i

and a personnel rcplacement capability.

Certain functions must be performed for all fires, i.e., command brigade actions, inform plant management, fire suppression, ventilation control, provide extra equipment, and account for possible injuries. Until a site specific review can be completed, an interim minimum fire brigade size of five persons has been established. This brigade size should provide a minimum working number of personnel to deal with those postulated fires in a typical presently operating commercial nuclear power station.

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i d if the brigace is composed of a snaller number of personnel, the fire' attack may be stopped whenever new equipment is needed or a person it injured or fatigued. 1:e note that in the career fire service, the rainimum engine company manning considerco to be effective.for an initial attack on a fire. is also five, including one officer and four team members.

It is assumed for the purposes of this position that brigade training and equipment is adequate and that a backup capability of trained individuals exist whether through plant personnel call back or from the local fire department.

POSIT 10U l.

The ninimum fire brigade shift size should be justified by an analysis of the plant specific f actors stated above f.or the plant, af ter modifications are ccmplete.

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In the interim, the minimum fire brigade shift size shall be five persons. These persons shall be fully qualified to perform their assigned responsibility, and shall include:

One Suocevisor - This individual must have fire tactics trainino.

He cili assume all command responsibilities for fighting the fire.

During plant oaeroencies, the origade supervisor should not have other responsibilities that would detract from his full attention being devoted to the fire.

This supervisor should not he actively engaged in the fighting of the fire.

His total function should be to survey the fire area ccamand the brigade, and keep the upper levels of plant management informed.

lwo liese Men - A 1.5 inch fire hose being handled within a window-less enclosure would reauire two trained individuals.

The two team mtabers are recuired to physically handle the active hose line and to protect each other while in the aoverse environment of the fi re.

Two Additional Team 'Icvbers - One of these individuals would be reouired to supply filleo air cylinders to the fire fighting members of tne brigade and the second to establish. smoke ventilation and aid in filling tne air cylinder.

These two individuals would also act as the first backup to the engaged team.

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