ML20037B285

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Safety Evaluation Supporting Amends to Licenses DPR-2,DPR-19 & DPR-25
ML20037B285
Person / Time
Site: Dresden  Constellation icon.png
Issue date: 12/02/1977
From:
Office of Nuclear Reactor Regulation
To:
Shared Package
ML20037B284 List:
References
NUDOCS 8009100946
Download: ML20037B285 (8)


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%... f SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SUPPORTING AMENDMENTS TO FACILITY OPERATING LICENSE NOS. OPR-2, DPR-19 AND DPR-25 (NMONWEALTH EDISON COMPANY DRESDEN NUCLEAR STATION UNIT NOS.1, 2 AND 3 DOCKET NOS. 50-10, 50-237 AND 50-249 INTRODUCTION Following a fire at the Browns Ferry Nuclear Station in March 1975, we initiated an evaluation of the need for improving the fire protection programs at til licensed nuclear power plants. As part of this continu-ing evaluation, in February 1976 we published a report entitled

" Recommendations Related to Browns Ferry Fire", HUREG-005U.

This report recommended that improvements in the areas of fire prevention and fire control be made in~most existing facilities and that consideration be given to design features that would increase the ability of nuclear facilities to witnstand fires..ithout the loss of important functions.

To implement the report's recontendations, the NRC initiated a, 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 guidelines reflect the recomm'endations in NUREG-0050.

These guidelines are contained in the following documents:

" Standard Review Plan for the Review 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.S-1), May 1,1976..

" Guidelines for Fire' Protection for Nuclear Power Plants"(Appendix A to BTP APCSB 9.S-1), August 23, 1976.

"Supplenenta'ry Guidance on Information Needed for Fire Protect 1on Program Evaluation," September 30, 1976.

" Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls and Quality Assurance," June 14, 1977.

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Commonwealth Edison Company (licensee) has submitted a description of the fire protection program for the Dresden Station, Units 1, 2 and 3 by letter dated September 30, 1977. This program is under detailed review by the NRC.

In the interim, until we ' complete our detailed review, we have concluded 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 systems.

In addition, the unendment would include administrative requirements for the implementation of the fire protection program.

By letters dated December 2,1976 and June 24, 1977,- we requested the-licensee to submit Technical Specifications for the presently-installed fire protection equipment at this facility, and provided sample Technical Specifications for their guidance.

Subsequently, the licensee proposed Technical Specifications by letter dated September 20, 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.

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. DISCUSSION AND EVALUATION The guidelines for technicd specifications that we ceveloped and sent to all licensees are based on assurino that the fire protection equip-ment currently installed -for the protection of safety related areas of the plant is operable. Tttis assurance is obtained by requiring periodic surveillance of the equipment and by requiring certain corrective actions to be tak'en if the limiting conditions for operation cannot be met.

These guidelines also inclu:!e administrative features for the overall fire protection program such as interim fire brigade requirements, training, procecures, management review and periodic independent fire protection and loss prevention program inspections.

The equipment and components currently existing at these facili, ties included '

in the scope of these Technical Specification requirements are fire detectors, the fire suppression systems, the hose stations, and piping and cabling 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 equipment. In the event that the minimum coverage of fire detectors cannot be met, hourly fire -

patrols are required in the affected area until the inoperable instrumentation is restored to operability. The operability. of the fire suppression systen 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 r,eport 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 protection to confine or retard fires from spreading to adjacent portions of the f scili 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 suppressicn in the event of a fire.

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Ue havs reviewed the licensee's' proposed interim Technical Specifi-s s

cations against our requirements as implemented in the sample

_We have made som; modifications to the Technical Specifications.

specifications that were proposed by, the lir.ensee in order to make them conform to our requirements.S Oreiof,the proposed specifications that we changed involves thefminimum size c' the

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on-site fire brigade.

In our previous sampi,e_ Technical Specifications u

we did not identify the number of mernbers on;a fire brigade that we would find acceptable. We have aow concluded that minimum i

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number for a' typical commercial nuclear poweh p1;4at'to,be five (5).

The basis for this conclusion is presented in ar, attaceent to this SER entitled " Staff Position Mihimum Fire Brigade Shif Size."

t NI In the report of the Special Revihw Group on the Brhw[s Ferry Fire (NUREG-0050) dated February 1976, consideration 'ofLthe safety of

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operation of all operating nuclear powet plants pendins the conpletion of our detailed. fire

  • protection evaluation,w's presented.

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The fo'3owing quotations from the report summarize Ahe basis for our

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cort 1Lsion that the operation of the plants, until'Qe, complete our g

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reyiew, does not present an undue risk to the health and safety of tr.e public.

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"A probability assessment of public safety 6, risk in

""' C'~ quantitative tems is given in the Reactor Safety Study

'i (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 radioactivit),

from such a fire is about 20%.of that calculated from all other causes analyzed. This indicates that predicted potential accident risks f' rom all causes were not')/ehtly 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.

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The study (WASH-1400) also points out that. 'rather straight-forward measures, such as may -already exist'at other nucleer plants, can significantly reduce tti likelihood' of a potential coreselt accident that mignt result from a large fi re. ', The Review Group agrees.

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

" Based on its review of the events transpiring before, during and after the Browns Ferry fire, the Review Group concludes that the probability of disruptive fires of 4

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 done the likelihood of disabling fires and to improve assurance

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Consideration of rapid extinguishment of fires that occur.

should be given also to features that would increase further the ability of nuclear facilities to withstand large fires without loss of important functions should

, such fires occur."

Subsequent to the Browns Ferry fire and prior to Special bulletins were sent steps with regard to fire protection.

24, 1975, and to all licensees of operating power reactors on March April 3,1975, directing the imposition of certain controls over-fire ignition sources, a review of procedures for controlling maintenance and modifications that might affect fire safety, a review of emergency procedures for alternate shutdown and cooling methads, and a revi of flammability of materials used in floor and wall cables and in penetration seals were completed at all operating power Special reactors in April and May 1975. Inspection findings which reflected non-compliance with NRC requirements resulted in requir are taking the required corrective actions and that administrative action by licensees.

i control procedures are in place.

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--y Since these inspection activities and the subsequent Special Review e

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 z

those conclusions is still adequate.

h Therefore, we.have found these specifications acceptable on an interim F

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 amen &nents do not authorize a We have determined that the planned 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 t of env,ironmental impact and' pursuant to 10 CFR 551.5(d)(4) that an enendments involve environmental impact statement or negative declaration issuance of these. planned amendments.

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

(1) because the snendments do not involve a significant increase in

'the probability or consequences of accidents previously considered involve a significant decresse in a safety margin, the not involve a significant hazards consideration, (2) and do not there, is reasonable assurance that the health and safety of the public amendments'do d (3) will not be endangered by operation in the proposed manner, an such activities will be conducted in compliance with the Commission's regulations and the issuance of these planned amendm of the public.

Staff Position - Minimum Fire Brigade Shift Size

Attachment:

Date: December 2,1977

Attactmen2

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s Staff Position Minimum Fire Gricade Shift Size _

INTRODUCTICN Nucicar power plants depend-on the response of an onsite fire brigade g

for defense against the effects of fire.on plant _ safe shutccunIn capabilities.

In other areas, that are orctected only means of fire suppression.

'by correctly designed autcmatic. detection and suppression systems, (1) fires " -

manual fire fighting efforts are used to extinguish:

small to actuate the automatic. system; (2) well developed fires if the -

auter.atic system fails to function; and (3) fires that are not completely Thus, an.adecuate fire brigade is controlled by the automatic system.

essential to fulfill the defense in depth requirements which protect -

safe shutdewn systems frca the effects of fires and their related combustion by-products.

DISCUSSION There are a number of factors that should be considered in establishing They include:

the minimum fire brigade shift size.

1) picnt gecmetry and size;2) cuantity and quality of detectica anf. suco
3) fire fighting strategics for postulated fires;
4) firc brigade training;
5) fire brigade eauipment; ar.d6) fire brigade supplements by plant per department ( s).

In all plants, the majority of postulated fires are in enclosed created by the heat and smoke bui'idi:p within the less structures.

and a personnel replacement capability.

Certain functions must be perfonred for all fires, i.

Until a site provide extra equipment, and account for possit,le i of five persons has been established.

a minimum working number of personnel to deal w

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If the brig:ce is comnosed of a smaller number of ' personnel, the fire attack may be scopped iteneve:r new equipment is needed or a person is 1-le note that in the career fire service, the minimum engine company manning considered to be effective for an initial injured cr fatigued.

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attack on a fire is also five, including one officer and four team nembers.

It is assumed for the purposes of this position that brigade training

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and equipment is adequate and that a backup capability of trained individuals exist whether thrcugh plant personnel call back or from 24 the local fire department.

gj POSITIOU The minimum fire brigade shif t size sheuld be justified by an analysis of the plant specific f actors stated above for the plant, after 1.

modifications are ccmplete.

In the interim, the minimum fire brigade shift size shall be five These persons snall be fully qualified to perform their 2.

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assigned responsibility, and shall include:

One Sunervisor This individual must have fire tactics training.

He wifi assume all command responsibilities for fighting the fire.

During plant emergencies, the brigace supervisor should not have other resconsibilities that would detract from his full attention This sucervisor should not be actively being devotes to the fire.

His total function should be engag7d in the fightiag of the fire.

to survey the fire area, ccmmand the brigade, and keep the' upper levels of plant management informed.

Twc Hose Men - A 1.5 inch fire hose being handled within a window-The two less enclosure would require two trained individuals.

team menbers are required to physically handle the active hose line and to protect each other while in the adverse environment of the fi re.

Two Additionci Team Memeers - One of these individuals would be recui?ca to sucoly filleo air cylinders to the fire fighting members of the brigade and the second to establish. smoke ventilation These two individuals would and af a in filling tne air cylinder.

also act as the first backup to the engaged team.