ML062280075

Evaluation of Minimum Fire Brigade Shift Size, June 8, 1979

ML062280075
Person / Time
Site:	Browns Ferry
Issue date:	06/08/1979
From:	- No Known Affiliation
To:	NRC/RGN-II
References
NUDOCS 7908130122
Download: ML062280075 (31)

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ATTACHMENT 3 EVALUATION OF MINIMUM FIRE BRIGADE SHIFT SIZE.

JUNE 8, 1979 I

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EVALUATION OF MINIMUM FIRE BRIGADE SHIFT SIZE Table of Contents I. Introduction II. Background III. Discussion A. Defense-In-Depth Principle B. Fire Brigade Performance Objective C. Fire Brigade Actions D. Typical Response to a Postulated Fire in a Nuclear Plant IV. Conclusion V. Appendix A - Staff Response to Licensee's Arguments

1. Historical Fires

2. Offsite Personnel

3. Availability of Onsite Personnel

ii' EVALUATION OF MINIIIM FIRE BRIGADE SHIFT SIZE INTRODUCTION Criterion 3 of the General Design Criteria (GDC) for Nuclear Power Plants (Appendix A to 10 CFR 50) reads as follows:

"Fireprotecti on. Structures, systems and components important to safety shal be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires and explosions. Noncombustible and heat resistant materials shall be used wherever practical throughout the unit, particularly in locations such as the containment and control room. Fire detection and fighting systems of appropriate capacity and capability shall be provided and designed to minimize the adverse effects of fires on structures, systems and components important to safety. Fire fighting systems shall be designed to assure that their rupture or inadvertent operation does not significantly impair the safety capability of these structures, systems, and components."

The above mentioned fire fighting systems consist of both automatic arnd manual systems. The minimum fire brigade shift is an essential part of the manual fire fighting system (i.e. , detectors, portable extinguishers, hose stations and fire brigade) which must function to aminimize the adverse effects of fires on structures, systems and components important to safety."

This evaluation summnarizes the staff's and its consultant's evaluation of the factors that establish the minimum fire brigade shift size. We have concluded that all operating plant sites should have an onsite fire brigade shift of at least five mnembders appropriately trained for fire fighting. The fire brigade shift should be capable of performing a spectrum of actions that may be necessary to cope with a variety of fire situations. One member should be assigned as fire brigade leader to assess the situation and direct fire fighting activities. Four members should be available to transport equipment to the fire, operate suppression equipment, or perform rescue work as required by the specific fire.

BACKGROIUND The need for and the role of the fire brigade as part of the fire protection program for operating plants has been under evaluation by the staff since the Brown's Ferry Fire in March 1975.

Following its study of the Brown's Ferry Fire, the Nuclear Regulatory Commission's Special Review Group Report, dated February 1976, stated the need for an adequate fire brigade:

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t..'lt ?ll - l . . . . . . . . -2 I1n addition to adequate equipment design, successful fire fighting requires testing and maintenance of the equipment and training and practice as teams under realistic conditions for

'the onsite and offsite personnel wjho must fight the fire. Onsite and offslte equipment should be compatible. -Emergency plans should recognize the need for fire fighting concurrent with other activities.

They should provide for division of available personnel into

-preassigned, trained teams responsible for the various activities needed with proper utilization of offsite fire-fighters." (NUREG-0050 "While the Review Group believes that such basic training is a necessary element in effective preparation for fire fighting, such training alone does not assure smooth operation of fire fighting personnel during a fire. Emergency plans should recognize the need for fire fighting concurrent with other activities. There must be a clear understanding of the duties of the onsite personnel, with preassigned and trained teams for each needed function. The degree of dependency upon trained onsite fire fighting personnel must be related to the-availability of support personnel from professional fire fighting units (city or county fire departments, military fire control units, etc.) or trained personnel in the licensee's organization who are available for such emergency service. In general, the onsite personnel should have sufficient training and practice to handle all small fires, and to contain larger fires until the offsite units arrive. When it Is deemed prudent to call in the offsite units, their capabilities should be used to the greatest extent possible.

Periodic drills, involving all onsite and offsite organizations which may be expected to respond to a fire, should be held to enable the groups to train as a team, permit the offsite personnel to become failar with the plant layout, and to permit evaluation of the effectiveness of comumunication among all those involved. These drills should include operations personnel, those specifically assigned to fire fighting, any offsite emergency control centers involved in the plan, and all those other organizations that would normally respond to such emergencies."

(NUREG-0050 p.27).

At Brown's Ferry Nuclear Station, a five man site fire Brigade was established to fight fires in any of the three units .on this site. To assure the presence of this fire brigade at all times, a requirement for such a fire brigade organization was incorporated into the Fire Protection Program for these units. Subsequently, in furtherance of the objective of GDC.3 the NRC reflected this need at all plants for an adequate fire briaade in all guidelines issued on fire protection (i.e., Branch Technical Position (BTP) 9.5-1, Appendix A to BTP 9.5-1 and Regulatory Guide (R.G.)

1.120.

These URC guidelines gave criteria for determining the size of the fire brigade:

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- The plant should be self-sufficient with respect to fire fighting activities and rely on public response only for supplemental or backup capability" (Appendix A p.7).

"Gudance, is contained In the following publications: National Fire Protection Association (NFPA) 27 - Private Fire Brigades" (Appendix A p.4).

Regarding the size of the fire brigade, NFPA 27 states: "The equipment that must be put into service at a fire will determine the number of men required for each operating unit or company into which the brigade is organized and the total number needed in the brigade. Each company should have a leader and each brigade should have a chief." (NFPA p.27-3, Vol. 12) (Note that the site fire brigade on each shift corresponds to the company of NFPA 27; the organization of all shift fire brigades corresponds to the brigade of NFPA 27.)

In November 1977, the NRC issued additional guidance indicating that the fire brigade size' should be determined by the functions the fire brigade must perform after consideration of several factors: (1) plant geometry and size; (2) quantity and quality of detection and suppression systems; (3) fire fighting strategies for postulated fires; (4) fire brigade training; (5) fire brigade equipment; and (6) fire brigade supplements by plant personnel and local fire depart-ments. At that time, the. staff established an interim fire brigade size of five persons until a site specific review could be completed.

In November 1977, the NRC sent licensees of operating facilities proposed interim Technical Specifications for fire protection which included the requirement for a five man fire brigade. The NRC position on Minimum Fire Brigade Shift Size was included with the Safety Evaluation supporting this requirements. The licensees' response on the requirement for a five man fire brigade was divided. Of 70 operating facilities,

.51 accepted a five man brigade and 19 presented arguments for a smaller fire brigade shift size. To effect expeditious implementation of interim Technical Specifications requirements for fire protection, license amendr*ents were issued which added Fire Protection Technical Specifications requiring the minimum fire brigade shift size as proposed by the licensees.

Where the licensee proposed a fire brigade of fewer than five persons, the amendments contained the condition that the staff's evaluation of the licensee's basis for the smaller fire brigade size would be included in the site specific review of the licensee's fire protection program.

In April 1978, the NRC issued additional guidance regarding the sharing of personnel required onsite for the purpose of plant operation, industrial security and fire fighting. These guidelines recognized that: (1) the plant requires a minimum number of personnel to be on the site to cope with either an operating, security or fire emergency; (2) the probability of an event which requires entire minimum shift of each discipline during the first 30 minutes of the event is low; and (3) the shift supervisor should be able to use available site personnel

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as the specific emergency demands.

Since October 22, 1976, the NRC fire protection review teams have visited all operating facilities. At each site, the staff evaluated the factors identified in its November 1977 guidance.*

We found that variations in plant geometry and size were not a determining factor for minimum fire brigade shift size because at all of the plants we found combinations of hazards, conditions of access, and physical arrangement of safety related equipment that would require immediate

-ý4actions by at least five persons. In all but a few plants, the detection and suppression systems and fire brigade strategies, training, equipment, supplementation. by off-shift personnel are about equal because

they met or committed to meet staff guidelines. In some cases, our site evaluation concluded that more than five persons were required for each shift; however, in these cases, prompt modifications were made by licensees to reduce the need for the additional mariower. None of the plants had support from local fire departments which .#as adequate to reduce the size of the fire brigade below five persons. All of the plants had sufficient support from local fire department and off shift personnel such that the minimum fire brigade shift size need not be increased above five.

We also found that the major factors in determining the shift size of the fire brigade were (1) the need for leadership of the brigade by a person who is relatively free of other duties, including actively fighting the fire; (2) the equipment to be obtained and used for fighting the fire; and (3) the actions to be performed by the fire brigade for a variety of fire situations.

The concept of "defense-in-depth" which has been utilized throughout the site specific evaluations contains three major areas of protection, i.e.,

prevention, detection and suppression. First, administrative controls are required to limit the quantity of combustible and potential ignition sources. Second, detection systems are required to inform the plant staff in the event of a fire. Third, suppression systems, primary and in some cases, secondary, are required to extinguish the fire rapidly and successfully. Each of these areas requires a minimum level to be accepted.

The fire brigade must have a minimum acceptable size, e.g., to be given credit for being able to perform its function under a broad spectrum of conditions.

The fire brigade is but one element of the"defense-in-depth" fire protec-tion program which contributes to the adequacy of the fire protection that assures that the public health and safety is not endangered due to potential consequences of fire at an operating facility. To consider this issue in perspective, it is necessary to remember that if a severe fire occurs, the plant conditions which lead to or result from the fire cannot be

• Some of the licensees arguments for a smaller shift size are discussed in Appendix A.

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precisely defined and that no single echelon of fire protection can be perfect or complete in itself.

The demands on the manual fire fighting capability and resources will vary depending on their,degree of involvement:

1. If the automatic detection and suppression system functions as designed, the combustibles involved in the fire are limited to those evaluated in the design, and all other conditions for the fire are the same as

.for the design evaluation, the fire will probably be controlled and possibly extinguished by the installed system. The fire brigade will be needed to enter the involved area to conduct final "mop-up" actions and inspection to ensure the fire is completely extinguished.

2. If the fire is of a larger magnitude than the design assumption of the automatic systems or the fire spreads beyond the coverage of the automatic system because of the deterioration of design conditions, the fire brigade will be required to assist in the extinguishment operation and possibly in the protection of adjacent safety related equipment which may be jeopardized by the fire.

3. If the automatic systems do not actuate, the fire brigade will be required to independently contain and extinguish the fire in the involved zone. Similar action is required in all areas that do not have automatic suppression systems.

When determining the minimum fire brigade size, each of the above three levels of performance 'must be considered and evaluated, with the third level bounding the brigade size since it places the largest burden on the team.

Further, the specific fire brigade actions that will be required will vary from area to area within the plant, and with the construction, maintenance or normal operation activities that may be ongoing at the time of the fire.

Because the specific fire brigade actions cannot be precisely defined, the fire brigade must be capable of a spectrum of actions that may be required. The minimum fire brigade and the available manual equipment is the only fire suppression system in many areas of the plant. Thus, the brigade and their equipment must satisfy the requirements of the General Design Criteria to minimize the adverse effects of fire on systems impor-tant to safety for these areas as well as provide its contribution to the defense-in-depth features in other areas which also have automatic suppression systems. The fire brigade offers the flexibility to perform actions to mitigate the consequences of fires for the event that may exceed the limits of fixed fire protection systems and with early warning fire detection, to extinguish fires before automatic systems actuate.

Even though ,ne fire brigade is only one aspect of the "defense-in-depth",

it requires a minimum operating size to successfully fulfill its perfor-mance objectives as defined in the following section of this document.

To reduce the size below the needed level will result in the loss of brigade flexibility and the potential that all performance objectives will not be achieved.

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B.,Fire Brigade Performance Objectives The performance objectives of the fire brigade at a nuclear power plant are the same as those in any fire situation. There are three major performance objectives: (1)rescue; (2)extinguish; and (3) confine,

.control and extinguish. Which of these objectives are to be performed depends upon the specific factors that are present at the fire; however, the orderof performance of these objectives never changes. Where there is no need for rescue, the first.objective can be "extinguish". In all cases, even the most extreme, the final objective always is to extinguish the fire. This is true even where it is first necessary to confine the fire, then bring it under control and finally extinguish it. In extremely rare and unusual circumstances, a fire may be allowed to burn itself out as a last resort. We have not endorsed this alternative as the design condition because of 'the potential deleterious effects on plant operation associated with the toxic and corrosive effects of the smoke and additional system failures that may occur.

To achieve any one, or all of the major objectives, the fire brigade must perform several functions. Some of these are:

(a) Locate the fire and ascertain its potential; (b) Localize the fire, alleviate smoke and heat conditions, improve visibility, and facilitate the advance of hose lines; (c) Extinguish the fire by application of a sufficient amount of the correct extinguishing medium; (d) Minimize damage by the judicious use of water or other extinguishing agent;

• (e) Protect personnel , provide ventilation, self-contained breathing equipment and protective backup capability;

• (f) Coordinate activities through adequate supervision and cormmunication.

To ascertain the potential of each specific fire, and to determine the required functions, there are certain primary factors that must be evaluated by the fire brigade leader at that time. Some of these primary factors are: life hazai for occupants and for personnel, location of fire, extent of fire on ,Ival, shutdown equipment and fixed suppression systems in the fire building, construction of fire building, construction of exposures, area of exposures, proximity of exposures, structural collapse of fire building, heat conditions, smoke conditions, visibility, exposure hazard, and class of fire.

• These are objectives from the beginning to the end of every fire suppression operation.

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1'- 7-Some of these factors interact and the combination of effects of such

'7 factors also require the consideration of the fire brigade leader.

C. Fire Brigade Actions The actions required of the fire brigade to achieve the performance objectives depend largely on the complexity of the fire; however, the shift fire brigade should be capable of performing a spectrum of actions for any fire.

If a fire alarm sounds for any area of the plant the following actions should be taken by the fire brigade:

(a) The fire brigade leader and all brigaoe members should irmediately respond to the fire area.

(b) The brigade leader should respond directly to the fire area, with an extinguisner that he obtains on the way, and with adequate equipment for co.-nunications and 3 portable handlight.

(c) The other brigade members should respond to the fire area with a personal self-contained breathing apparatus and a portable extinguisher.

If on arrival at the fire area, an incipient fire is in Drogress, the following actions should be taken by the fire brigade:

(a) An iumediate attach should be made on the fire in an attempt to extinguish.

(b) Additional extinguishers should be obtained from the immediate area.

(c) A hose line should be stretched to the fire area as a precaution.

(d) Additional self-contained breathing apparatus and spare cylinders should be obtained inmnediately to be ready for use if necessary.

If the fire is not extinguished in its incipient stage, the following actions may be required:

(a) Place the necessary calls for off-site assistance.

(b) If ladders are required to reach the fire, fire ladders should be obtained.

(c) If the fire involves electrical equipment, the equipment should be de-energized. This action requires coordination with operating personnel to assure it will not affect the continued safe operation of the plant.

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.,'~ ,. I (d) If smoke conditions 'are such that visibility is impaired, ventilation may be required either in the form of activation of fixed systems or by the use of portable smoke ejectors.

(e) If it becomes necessary to use water fog, precautions should be taken to prevent water damage to electrical equipment not involved in the fire. This may require the use of protective water shielding.

(f) If it becomes necessary to use water fog, a second hose line, from a standpipe or exterior hose station should be prepared to serve as a back up to the initial hose line.

(g) If the fire area is one that contains a special hazard such as a flammable or combustible liquids, some of the brigade members should obtain and prepare the special equipment necessary for that type of operation, i.e.,!foam in 5 gallon c3ns, pick up tube, foam

-applicator and hose lines.

(h) If the fire is in a confined space and its exact location cannot readily be determined, the fire brigade leader may commit all his personnel to the attempt to locate the fire, but should do so only after all other required preparatory actions have been carried out.

(I) If any of the brigade members, who are actively extinguishing the fire or attempting to locate the fire, become trapped or incapacitated in anyway, other brigade members would be required to rescue. If the injury were such that the injured party were overcome by smoke or severely injured, at least one of the other members would be required to attend the injured to attempt to safe his life.

(j) If the fire has not been extinguished when offsite assistance arrives at the fire location, the offsite people should be divided into teams to assist the fire fighting operation with each team having a member of the plant brigade assigned as leader.

For any given area or fire, the initial actions of the brigade require sufficient personnel to extinguish the i ncipient fire and to prepare for the fire that may occur if the Incipient fire is not extinguished. Therefore, the brigade should be adequately staffet I so that the above actions can be performed if required by a particular fi Table I indicates how these required actions would be carried out by a five member fire brigade. Not all actions assigned to each member will necessarily be carried out for every fire; however, for the spectrum of fires that may reasonably be expected to o-cur, the brigade should be capable of performing the actions as shown. The five member fire brigade is the minimum complement that can provide sufficient personnel so that these actions may be carried out.

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D Typical Response to a Postulated Fire in a Nuclear Plant The following outline describes how a brigade would respond to a postulated fire and carry out the actions discussed in the previous sections. The outline illustrates the need for some actions simultaneously and some sequentially. It also illustrates that the specific circumstances that determines the course of the fire will determine the specific actions required. The actions being performed by the fire brigade leader and the fire brigade members are summarized in Table 1.

I. The fire brigade leader and all brigade members should initiate their response to the announced fire area.

2. The fire brigade leader should respond directly to the announced fire area with portable communication equipment. He evaluates the situation, and advises the control room and formulates an action plan.

3. Each member of the fire brigade including the fire brigade leader obtains a fire extinguisher from a location along the way and bring it to the fire area. These rhould be brought from a remote lncation to assure that sufficient extinguishers will be available. Those in

.1he immediate fire area may have been used by the discoverer rithe fire.

4. Each member of the fire brigade should also bring a self-contained breathing apparatus for use by the brigade members.

5. If conditions are such that self-contained breathing apparatus masks will have to be worn by the brigade members, no member should enter the fire area without a mask. If necessary one or more, depending on the need, brigade members should be sent to obtain additional self-contained breathing apparatus in sufficient number so that each brigade member and the fire brigade leader will have a unit.

At least one man should be sent to obtain spare air cylinders, at least one per self-contained breathing apparatus being used. (NOTE:

Recent tests at Syracuse Fire Dept. Training Academy showed that the 1/2 hour rated mask, pressure demand type, was breathed down in as little as 7 to 15 minutes during fire fighting activities).

6. If the brigade members will pass by the personnel protective clothing storage area, they should obtain their fire fighting gear and bring it to the fire scene. If such clothing is needed but is not brought to the scene, at least one man should be sent to obtain such clothing.

7. If the source of the fire or smoke can be readily determined, the brigade leader should order the following simultaneous actions-(a) At least two (2) man to begin a direct attack on the fire with suitable extinguishers and, (b) the remaining two (2) men to prepare to assist with additional extinguishers and/or to stretch at least one 1-1/2" standpipe hose line to be used as a back up to the extinguishers.

If the fire is readily extinguished by the initial extinguisher application, the brigade leader should make a careful examina-tion of the fire area to insure that the fire has been completely extinguished and to try to determine the point of origin and the cause of the fire. He would be assisted by at least one brigade member. Consideration should be given for the need for a fire watch in the area for a period of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

The remaining brigade members would be directed to return the fire fighting equipment brought to the fire location to its proper storage area ensuring that it is in proper working order and in readiness for another fire.

A critique of the fire fighting operation should be held i*.,mediately after the fire to evaluate the pre-fire strategies for the fire area and to determine the efficiency of the fire brigade and the effec .fveness of the operation.

8. If the smoke conditions are such that the location of the ource of the fire and smoke cannot readily be determined, the bi gade leader should order the following simultaneous actions:

(a) The control room to :notify the off-site fire departvent and plant on-call personnel.

(b) Two brigade members and the leader to put on self-contained breathing apparatus, take suitable extinguishers and enter the fire area to attempt to locate the fire.

(c) The remaining brigade members to put on self-contained breathing apparatus and stretch a 1-1/2" hose line from the clcsest standpipe location and assure that the hose has sufficient length to effectively reach the fire area.

(d) After the hose line is stretched and ready to be operated, at least one member should remain with the line while the other(s) go to obtain additional equipment usch as smoke ejectors, ladders if necessary, spare air cylinders, protective covers for water sensitive equipment, and any other items that would be of need in the fire and damage control effort.

(e) If while the above activity is going on- the fire source is located by the leader and the two brigade members, they would immediately attempt to extinguish the fire with their extinguishers. (If successful, the steps subsequent to extinguish-ment outlined in 7 above would be followdd).

9. If the fire is not readily extinguished by the use of extinguishers, the following actions should be undertaken by the fire brigade as ordered by the fire brigade leader.

(a) The 1-1/2" hose line that has been stretched as a pre-cauthionary measure should be advanced into the fire area by at least two brigade members and; (b) The remaining brigade merbers should simultaneously stretch an additional 1-1/2" hose line from the closest available standpipe location to the area immediately outside or adjacent to the ,fire area and be prepared to use this line to provide protective sptay and/or as a backup attack line if the fire severity demands. (N4OTE: It is likely that the second 1-1/2" hose line will have to have additional hose added to reach the fire area).

(c) Once the second line is readied for use and if its immediate use is not required, the fire brigade leader may direct one or more of the back up men to take steps to pro-vide protection for electrical equipment or to set up portable ventilation equipment to evacuate smoke and heat, or to obtain additional special equiprent that may be required if the fire is not controlled and ex*inguished in a short time.

(d) If the brigade leader ant the men attacking the fire with the 1-1/2" hose line are successful in extinguishing the fire, the steps subst4uent to extinguishment obtained in 7 above should be fol )wed.

10. If the fire is not extinguished by the attack with 1-1/2" hose lines, the area may become untenable as a result of either heat or smoke or both. In this situation the fire brigade leader should order the following actions by the fire brigade.

(a) All personnel should back out of the fire area and take positions where they can either keep the fire contained by the use of the hose lines from the perimeter openings or (b) The area should be sealed off, if possible, by closing the fire doors and the hose 'ines should be used by brigade members to attempt to keep the fire from passing through any penetrations or ducts or fire doors or the exterior walls by spraying water on the potentially dangerous areas to keep it cooled down.

(c) If the situation develops to this extent in a relatively short time period (less than 15-20 minutes) it may be necessary for the brigade leader to direct that one individual hold the 1-1/2" hose line from a suitable braced position while the other members are sent for additional back up hose lines, additional air supply, and to check surrounding areas and floors above the fire for possible extension of the fire.

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, 12 (d) The fire righting objective would now become a matter of confine, control and extinguish (or allow to burn out). When this occurs there will be a very serious problem of smoke and heat removal which will require the efforts of all available personnel as they arrive from off-site.

(e) Decisions will have to be made regarding the direction the smoke and heat is to be routed with serious consideration given to the possible damage the smoke and/or heat might cause to equipment that is relatively remote from the fire.

CONCLUS ION On the basis of its onsite evaluations of the fire protection program for 70 operating facilities, the NRC staff has found that:

1. The specific actions for the control and extinguishment of potential fires vary greatly from area to area within a given plant;

2. The specific actions which the fire brigade may be required cannot be precisely defined prior to the fire;

3. Although the fire fighting actions as described previously in this report may not be applicable to each and every plant area, all plants contain areas important to plant safety which require consideration of these fire fighting actions.

4. Abnormal events cinnot be precluded for each and every potential fire situation, some margin in brigade size is warranted to compensate for the potential unanticipated events such as:

a. Failure of detection systems to promptly alert plant personnel of the onset of a fire condition.

b. Failure of automatic suppression systems to actuate to limit fire damage.

c. Personnel injury in the act of fire fighting.

d. Failure of administrative controls of combustible materials in situations which could impact systems important to safety.

5. The minimum fire brigade shift size cannot be based only upon the potential fire consequences and their adjacent impact on the capability to safely shutdown because this is contradictory to both the philosophy of defense-in-depth and the general design criterion requirement to minimize the adverse effects of fires.

Based on the above, we conclude that:

1. All operating plant sites should have an onsite fire briagde shift complement of at least five trained persons.

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2. One member should'be assigned as fire brigade leader and at the time of the fire, he should be free of all duties so that he can devote his attention to assessment of the fire situation and direction of fire fighting activities.

3. Four members should be capable of acting individually or as teams to perform the spectrum of basic fire fighting action which may be required e.g., locating the fire, operation of portable extinguisher or hose lines, transporting equipment to the fire scene, or rescue work.

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41 TABLE I MANPOWER REQUIRED FOR FIRE FIGHTING ACTIONS FIRST & SECOND BRIGADE THIRD & FOURTH BRIGADE LEADER MEMBERS MEMBERS A. ACTIONS REQUIRF1 FOR FIRE NOT EXTINGUISHED BY PERSON(s) WHO DISCOVERED FIRE.

Respond to fire with portable Respond to fire with portable fire Respond to fire with portable.

fire extinguisher extinguishers. fire extinguishers.

Respond to fire with self- Respond to fire with self- Respond to fire with self-contained breating apparatus. contained breathing apparatus. contained breathing apparatus.

Locate fire or source of smoke Locate fire or source of smoke. Locate fire or source of smoke..,.

Evaluate the fire situation and Operate fire extinguishers on the Operate fire extinguishers on the the area involved to determine the fire (if fire location is deter- fire (if fire location is deter-effective actions to be taken and mined). mined).

maintain communication with control room.. (Required for all Stretch at least- one 1-1/2" fires. hose line to be used as back-up to extinguishers.

Direct fire fighting activities by the fire brigade members.

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B. DDIIONAL ACTIONS REQUIRED FOR FIRE NOT EXTINGUISHED WITH PORTABLE EXTINGUISHERS At the scene of the fire, continuously Extend and prepare Obtain fire fighting protective evaluate the fire condition as it to operate a 1-112" hose line or a clothing for fire brigade developes. Direct the activities of single 2-1/2" hose line from an members. (If not brought on the other members and observe the fire exterior hose house. 1st response).

fighting operation and judge its effectiveness and safety. Consider Attempt fire extinguishment as a Obtain special equipmentfor fire .

alternative actions that may be two person team use one fire hose. fighting operations - ladder,:

required as a result of changing foam, ventilation, breathing air.

_cndWitions.

s Consider the consequences.

of actions being taken in regard to Take steps to Cover electrical their impact on the overall safe shutdown equipment to prevent water damage.

capability of the plant.

When necessary, extend and The fire team leader should not be- prepare to operate a 1-1/2" hose come involved in the actual fire line or a single 2-1/2" hose ftghtirgprocess to the extent that line from an exterior hose house.

he is unable to carry out the responsibilities of continuous Perform relief and rescue duties evaluation and decision making. as required.

Communicate with control room regarding fire status, equipment that may become disabled, need for off-site assistance, etc.

Ii 11 C. AQOITIONAL ACTIONS REQUIRED FOR FIRE THAT DEMANDS ASSISTANCE BY OFF-SITE PERSONNEL All act'lons required in B:

Be prepared to provide rescue of en- Be prepared to provide rescue of Be prepared to provide rescue..

dangered personnel or fire brigade dangered personnel or fire brigade of endangered personnel or fire members if necessary. members if necessary. brigade members if necessary...

Provide off-site fire fighting with Serve as guide, coordinator and Serve as guide, coordinator and sufficient information so they.under- control.-person for..off-site fire.. ..... contrqol_ person for off-site .fire stand the situation as it exists on department. department.

their arrival, the objective of the operation, the actions being taken to Isolate and confine fire. Isolate and confine fire.

achieve the objective, advice and supervision of their actions in Use hoses to cool and protect Use hoses to cool and protect coordination with the fire brigade. barriers. barriers.

Survey barriers for possible Survey barriers for possible break through and extentlon of fire break through and extention of fir, FOOTNOTES: Operations in fire areas should always be a team effort of at least two If these two members are not members for the purpose of improved operation and personal safety. fully trained fire brigade members, they would be replace by the off-shift personnel when they arrive.

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APPENDIX A STAFF RESPONSEITO SELECTED LICENSEE'S ARGUMENTS Historical Fires Some licensees argue that the majority of historical fires in nuclear power plants were either self-extinguished or were extinguished by a small response force. Further, a large number of these fires occurred during the construction phase of the plants.

The URC does not deem the size of historical fires a significant factor in determining the size of the minimum fire brigade. The small fires that self-extinguish or the fire- that are easily extinguished presenIt little, if any, threat to public health and safety.

Further, the circumstances that lead to fires in the construction phase are not precluded after the plant goes into operation. New construction at the site, major plant modifications and maintenance activities produce Isimilar circumstances at an operating plant.

It is the fires that do not-;self-extinguish because of "off-design" conditions or are not promptly extinguished at operating plant sites which may present a threat to the plants capability to achieve and maintain safe shutdown conditions. For example, a temporary breakdown in the administrative controls over the use of combustibles and ignition sourcea failure to detect a fire early, or adverse unanticipated events which either delay prompt extinguishment or lead to rapid fire'development may lead toward the development of a severe fire.

Because of the possibility of these fires, the staff deems it prudent to maintain a site fire brigade which can promptly extinguish such fires In safety related areas with sufficient margin in size to account for adverse conditions and events.

2. Offslte Assistance!

Some licensees argue that the minimum fire brigade may be less than five persons because of substantial offsite assistance.

The NRC concludes that the delay In prompt fire extinguishment incurred by reliance upon support from offsite fire departments or the call back or plant personnel does not provide an acceptable alternative to meeting the minimum manpower requirements for an onsite fire brigade.

Offsite fire departments could be committed to fighting fire elsewhere when a call goes out for their assistance. In many areas weather conditions could delay the -response of offsite fire departments as well as operating personnel called back for additional assistance. While the NRC recognizes the importance of a

('2 preplanned utilizition of offsite fire departments and call back Y".* personnel, such asisistance does not justify a reduction of an adequate onsite fire brigade to provide an inipediate initial attack on a fire.

3. Availability of Onsite Personnel Some licensees argue that the potential for fire is greater during

-. times when there is more than the minimum complement of plant operating personnel on onsite. In general,* this is the period from about 8 to 5 on normal work days. It is during these periods during which normal maintenance operations are performed.

While the NRC recognizes the greater potential for fire during such time, this does not alleviate'the need for an adequate fire brigade on the.other shifts. It appears that there are sufficient personnel on site on all shifts to provide a five man fire brigade.

In its position paper on "Maupower Requirements for Operating Reactors" the NRC addressed the sharing of available onsite personnel such as the security forces as a Mbeans of meeting the manpower require-ments for a five man fire brigade. The issue is not the availability of onsite personnel who could be utilized to combat fires; but rather the effective utilization of jnanpower resources to establish a trained team that responds to a fire and effectively performs those action which are essential to fire fighting.

.STAFF. POSITION MINIMUM FIRE BRIGADE TRAINING

~ CONCERN S rf During our evaluation ofi the training given to fire brigade members, the

..issue of whether all members of a five man fire brigade need be given i",i 'ldentical training has been considered. In several instances licensees W.47 k

Shave proposed two levels of training for fire brigade members. These evaluations have established the minimum acceptable level of training.

STAFF POSITION i-i We prefer that all fire brigade members receive training in accordance with the staff forth in "Nuclear guideline's setAdministrative Plant and Protection FireQuality Functional Responsibilities, Controls SAssurance," June 14, 1977:

. Attachment 1. Fire Protection Organization f,,* W Attachment 2. Fire Brigade Training

. Attachment 5. Fire Fighting Procedures (Note: Copies of these attachments are enclosed)

Where the five man firebrigade has two levels of training, at least

, three members shall have training which fully conforms to the staff guidelines; however, two members may be expected from the training require-ments listed below:

1. Attachment 2:

" . ' l.Oa (6) The direction and coordination of the fire fighting activities.

lOa (9) Detailed review of fire fighting procedures and l.Oa ( 1 0)procedure changes.*

,.Oa (10) Review; of latest plant modifications and changes in fire fighting plants.

The excepted personnel should have general training in these subjects.

R~

• The only portion of this item excepted is that associated with the fire fighting strategies. which have been developed to conform with attachment 5, item d. The strategies established for fighting fires in all safety-7%L" i"', related areas and areas presenting a hazard to safety-related equip-

. - . ment.

Iýd.

Excerpts from:

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

Attachment 1. Fire Protection Organization

- Attachment 2. Fire Brigade Training S..

.Attachment S. Fire Fighting Procedures Aamtzi

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Attachment No.1

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• FIRE PROTECTIO, ORGANiZATO:I 1.0 The organi.zational responsibilities and lines of conmunication per-tahing to fire protection should be defined between the various positions through the use of organizational charts and functional descriptions of eacn position's responsibilities. As a minimum the pasitions/organiut'ions responsible for the following should be designated:

a. The upper level offsite mana eren: posit*on which has management

":s"si.lity for the for-iult'on. irplementation, and assess-

. ment of the effectiveness of the nuclear plan: fire protection gprram.

b. The offsite management position(s) ditrectly responsible for

• (1) formulatIng, implementing, and periodically assessing the effectiveness of tne fire protection program for the licensee's nuclear power plant including fire drills and training con.

of these assessments should be reoorted to the upper level

,imanage'ent position responsille for fire protection with reco-menldations for improvements or corrective actions as deemed necessary.

S1(2) Using *Ite following NFPA Publicatlons for guidance to dev-elop tne fire protection program:

No, 4 - "Organization for Fire Services"

-40o. 4A  :"Organization of a Fire Oeparuient"

'o. 6 ,a"Industrial Fire Loss Prevention" No. 7 "1 management of Fire Emergencies" tic. 8 * "Management Responsibilities for Effects of Fire on Operations" No. 27 * "Private Fire Brigades"

c. The onsite management position responsible for the overall

,-administration of the plant operations and emergency plans which include the fire protection and prevention program and which provides a single point of control and contact for all contingencies.

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d. The onsite positiorr I'Which:

(1) implements periodic inspections to: minimize the amount of combusitibles in safety related areas; determine the efWectlveness of housekeeoing practices; assure the avail-ability and acceptable condition of all fire protection systems/equipment, emergency breathing apparatus, emergency lighting, communication equipment, fire stops, penetration and seals anr fire retardant coatings; and assures prompt conditions effective corrective actions are taken to correct adverse'to fire protection and preclude their recurrence.

(2) is responsible for the fire fighting training for operating plant personnel and the plant's fire brigade; design and selection of equipment; periodic insoection and testing of fire protection systems and equipment in accordance with established procedures and evaluate test results and deter-mine the acceptability of the systems under test.

(3) assists in the Critique of all fire drills to determine how well the training objectives have been ,et.

(4) reviews and evaluates proposed work activities to identify potential transient fire loads.

(5) implements a program for indoctrination of all plant contractor personnel in appropriate administrative pro-ceduresiwhich implement the fire protection program, and the emergency procedures relative to fire protection.

(6) implements a program for instruction of personnel on the

r

ter handling of accidental events such as leaks or spills of flammable materials that are related to fire I

protection.

3 I. e. The onsite ýcsition responsible for fire protection quality

a. assurance.

• S This position should be responsible for assuring the effective implementation of the fire protection program by planned in-spections and scheduled audits. He should assure and verify that results of these inspections or audits are promptly re-ported to cognizant management personnel.

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f. The positicns which are part of the plant fire brigade for (1) The plant fire brigade positions should be responsible of each fignting fires. The authority and res;cnsibility should fire brigade position relative to fire protection be clearly defined.

(2) The responslbilitles of each fire brigade positionfignting should Correspond with tne actions required by the fire procedures.

(3) The responsibilities of the fire brigadt -!- ers uncer normal plant conditions, should not, conflic. with their responsibilitiesduring a fire emergency.

(4) The minimum number of trained fire brigade members avail-able onsite for each operating shift should be consistent with Ve activitges required to comrat the most significant fire. The size of the fire brigade should be based upon the functions required to fight fires with adequate allow-ance for injuries.

(5) The recorrendations for organization, training, and equip-ment of "PR'IVATE FIRE BSIGACES" as specified in HFPA N4o. 27-1975, including the acplicable NF*A publications listed in the Appendix to HiFPA No. 27, are considered or;anizing, training, and operating brl;..de. for aporoorlate criteria fire a plant Z.O Qualifications

a. The position responsible for formulation and witnin imolenentation of the Fire Protection Program should have, his organ-ization, or as a consultant, a Fire Protection Engineer is a graduate of an engineering curriculum of accepted standing and shall have complete( not less than six years of engineering attainment indicative of growth in engineering competency and achievement, tbree of which shall have been in responsible charge of fire protection engineering work. These requirements are the eligibility'requirements as a Member in the Society of Fire Protection Engineers.

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, :*.*b. 'The ,fire br'i,-ae memoers qiualifications Should includte salts-

" *:*.,*~-_,"**:::faceoryv completion of a pnysical examination for performing

• i-i:**::**,!*i'i*strenuous activity, and of th~e fire brigade taining'cfescribed in

c. The personnel res;onstble for the maintenance and testing of the

. F..Fire Prozectionh'ystems should be qualified by training and ex;erience fcr Such work.

• d. The personnel res:onsible for the training of the fire brigade snould be qualified by training and experience for such work.

41 U.),'

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Attachment iNo. 2 F;RE BRIMA"N TR.AINIUG

`Phe training vro;ram should assure that the ceaabillty to fignt potential fires is estaiiished and maintained. 'the ;rogram. should c.jnsist of an

-initial cla- room instruction program followel by ;eriodic classroom P:1~. practice in fire fighting and fire drills:

4nt 1.0.assrocm Instruction A. The initial classroom. inst'ruction should include:

(1) Identification of the fire he,*Ards and associato ed typIes of fires tha:. could occur in t ne plar.: and an icenti-ficationm of tr e lccan on of suciy% hazards.

(,n) Identification of trte location of fire fighting eqjrps

. ent

. for each fire area, and familiarization with layout of the plan: Including access and egress routes to each area.

(3) The proper use of available tire fighting equipment, and thae orrectf ethod of fighting each type of fire. The types of fires c-vered snould Include electrical fires.

fires in cables ead cable trays, hydrogen fires, flam-renble liquid, waStefdetris fires, and record file fires.

(4),IndoctrInation of the plant fire fighting Ilan with specific co.eraoe of eaci Individual's res;cnsibiaretes (5) The proper use of comunication. lightinge ventilation

• and emergency breat~hing equipment.

(6) The direction and coordination, of the fire fignting activitieso (fire brigade leaders only).

(7) The toxic characteristics of eepecte, products of combustion.

(8) The proper method for fighting fires inside buildings

i and tunnels.

, (9) Detailed review of fire fighting procedures and procedure changes.

7) + *'.

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oexpcte. prducs o .

(10) Review of latest plant modifications and changes in fire fighting plans.

• 2 individuals

b. The instru.ctlon shnou1d be provided by qualified in fighting kncwled;eaole, exnerienced, and suitablythetrained plant and in using the ty;tes of fires that could occur in plant.

the types of equipment availaole in the nuclear power Brigade Leaders Me-*ers of the "Fire Protection Staff" and Fire may conduct this training.

c. Instruction should be provided to all fire brigade members and fire briga.e leaders.

repeat

d. Re;gular planned meetings held every 3 mcntns shouldperioa.

tne :lassr:cm instruction program over a two year 2.0 r.C~'ct.

on the Practice sessions should be held for fire brigade members similar mag-Prooer metnod of fighting various types of fires of nitude. co.'lexity,.and difficulty as tnose which could occur in brigade members a nuclear acwer plano. These sessions should provide and the use of em-with ex;e-lence in actual fire extinguisnment strenuous conditions. These ergency breatning apoaratus under at regular intervals but not practice sessiens snould be provided to exct.. I year for eacl fire brigace mener.

3.0 DrilIs Fire brigade drills should be performedDrills in the plant so that the fire brigade can practi.ce as A team. should Include the following:

notify

a. Assessment of fire alarm effectiveness, time requiredandto use of and assemoly fire brigade, and selection, placement equipmen..

the fire

b. Assess each brigade member-s knowledge of his role in to contain the fire-fighting strategy for the area assu.ed plant Assess %he brigade members conformance with established fire fighting procedures and use of fire fighting equipment, czrniuni-including self-contained emergency breathing apparatus, extent cation equipment, and ventilation equip-ment, to the practiCable.

)'

3 to cote C. The sinula:ed use of fire fignting equipment required the drill.

with the situatlon ana type -of fire selected for be varied The area and type of fire chosen for the drill should in all sucn tnat brigace -ne.ers are trained in fighting fires significant fire hazards. The safety related areas containing and arrangement situation selected should simulate the size of a fire wnich could reasonably occur in the area selected, due to the time required to re-allowing for fire development organize for the fire, assuming Spono. to obtain equipment, and loss of au:z-..-tic~suppression capability.

fighting

d. Assessment cf brigade leader's direction of the fire ef'ort, as to tnorougnness, accuracy, and effectiveness.

not

e. The drills shculd be performed at regular intervals but. drill to exceed 3 months for each fire brigade.shift" At least one per year should be perform*d on a 'back for each fire brigade. A sufficient number of these drills, not less than one shall be unannounced, to de-for eacn fire brig,.e per year, leader, termine the fire readiness of the plant fire brigade brigade, fire protection systems and equipment.

f. The drills should be pre-planned to establish the training

• objectives of tne drill. The drills should be critiqued.:o Cetermine how well the training objectives have performed been met.

by Unannounced drills Should have tr-eir critiques for plant safety me...ers of the canage-ent staff responsible critiqued and security. At three year intervals, drills should be staff.

by qualifie: individuals independent of the utility's 4.0 ;ecor,!s I

ecorcs of trainlngiprovided to each fireassure brigade member including drill criti;ues should be maintained to that each ,me..er These receives training in all parts of the training program.

recor:s of training. snoul.d be available for review.

man ARNWAM-

Atuac1,ent, No. 5 FIRE jF:GH. :NG PRCCTURE3 Fire fgntirng ;recramtes smduld te establtsied to cover suCe items as notification of a fire, firr emer;ency ;rccedures, and czoraination of fire fiptin; activities with cffsite fire Ce:artments. The fire fiit.-

ing ;rocecures sncwlC ictntlffy:

C. Actions to te taken1 by individual discovering the fire, sucm as. nctification of control room, atte.r=.t to extinguish fire, anc actu;a*on of local fire suz;ression systems.

b. Acticns to =e taken by the c.ntrl room 0Oerator and the-neec for trigace assis:ance uton rezrct of a fire or receipt of alarm on c:nzrcl rcm annunc.atzr panel, such as: announcing location of fire 6ver PA system, scundIn; fire alarms and nctifying tne shirIf. su;e-isor an: the fire brigade leader of the ty;e, si:e, and lo*ition of the fire.

c. Actions to Ve tzkel by the fire brigade after notification'by the :o:nrol rovm 'Ferator of a fire. including: locttion to assea:le; d¢rectizps given by fire crigade leacer; and res;cnsi-bilities of triga:ý ele.Ers such as seetifon of fire fignhting equ4:=ent Inc trans:crtation to'fire location, sele..ion of prto:ective ecul;:ept, use of fire sutoression systems operating sn:f. use of ;re;lanned strateoies for fighting insirunctios, fires in s;e:44fic areas.

a. The strate*Ies estAnlished for fi;gting fires In all safety-relatze areas and areas presenting a na:ar! to safety-related equi;ment. As a minimum the following suzjects should be czverec: i (1) lcentificaticn of combustibles in each plant zone covered by the s;etific fire filnptng procecures.

(2) Fire extinuishants test suited for cntrolling the fires associate with the Cccous~tible loadings in that Zone and the nearest location of these extinguisnants.

(3) Most favorable direction from which to attack a fire in each area, Inview of the ventilation direction, access hallways, stairs and doors which art most likely to be fire-free, Iard the best stAtion or elevation for fighting the fire. A specific identification system shall designate all hallways, stairs, doors, fire equitment and system control lecations, and other Items described In the fire fig*ting ;r:tcures. This I~ettfcation should be used -', '-

POOR BR1I1NML

0 . .

4 in the prccelures ano the czrresioaning plant items should be prcminently marked so, that they can be reccgnizec in

.dim light. All ac:ass and egress routes that involve lccked doors should be specifically identified in the procedure with the a;;ro;riate precautions and aetnoco fcr ac:ess s;eciflec.

( Desigr D) af plant systems that should be managed to reduce -.darna;e potential during a local fire; locition of local anc remote c:ntrzls for such Manage-ment (e.g..

any hycraulic or electrical systems in the zone covered by the spectfic fire fightin; procedure that could increase the ha:zi"s in the area because of overpres-surization or electrical ha:arcs).

(3) Oesi;vti(n of vital heat-sensitive system Ccmr:nents that should be ke:: c:ol while fignting a local fire.

Critical ezui;ment vnicn are particularly hazarcous c:mrustIble scurzes stculd be designate: to receive c.olin;.

(*} Cr;anizaticn of fire fignhtng brigades and the assigrment of snecial dutles accorCing to.Jot title so that all fire fignting functions are =ovrted by any c (zlete shift -er-sonnel coz=1ement. These duties shculd include cowanc c:ntrol of the brl;ade, fire hose laying, &;;lyingthe extinguishan: to the fire, advancing sur-ort supplies to the fire scene, c:unication with the c:ntrol room, ccraination with outside fire detartments.

(7) Identification radiological and toxic hazards in fire zones.

(a) Ventilation system operation that assures cesired plant pressure distriMtion wftn the ventilation flcw is modified for fire contairizent or szoke clearing cperations.

(9) Operations requiring control room and shift engineer c--lination or authorization.

(10) Instructions for plant operators and general plant per-sunnel Curing fire.

e. The validity of the ;reolanning strategies should be tested by accropriate full-dress drills to check the loic of tahe stratey, the adequacy of the equipment, personnel uncer- )

standing, and to uncover unforeseen problems.

K),.'-

P~oRORIGINAL