ML14190A371
| ML14190A371 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 01/21/1980 |
| From: | Lainas G Office of Nuclear Reactor Regulation |
| To: | Schwencer A Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8003070290 | |
| Download: ML14190A371 (17) | |
Text
DISTRIBUTION Central fil e NRCPDR PSB Reading J42 1 1980 MEMORANDUM FOR: A. Schwencer, Chief, Operating Reactors Branch #1.,
DOR FROM: -
G. Lainas, Chief, Plant Systems Branch, DOR
SUBJECT:
FIRE PROTECTION REVIEW - H.B. ROBINSON, UNIT 2.
Facility:
H.B. Robinson, Unit 2 Docket No.:
50-261, 1\\ -.-
Licensee:* Carolina Power and Light Company Responsible Branch: ORB#l Uf Project Manager:. D. Neighbors,
ReviewingBranch:
Plant Systems Status of Review: SER issued; Evaluation of supplement items is on-going Our evaluation of the licensee' ssubmittals listed in Enclosure 1 is.
complete. The results of our evaluation are attached (Enclosures 2, 3 and 4). presents our evaluation of issues that are complete. Enclosure 3 presents our evaluation of'issues for which we need additional information and,indicates the information required. presehts our evaluation for which the licensee's proposals are unacceptable and indicates requirements that would resolve the issue..
We request a response within 20 days if these requirements will be satisfied. Should the licensee choose not to satisfy any of these requirements, a meeting should be arranged within the same 20 days with appropriate management individuals prior to initiating an order.
Current status of the SER supplement items is summarized in Enclosure 1.
G. Lainas, Chief Plant Systems Branch Division of Operating Reactors
Enclosures:
As stated Cintact:
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 JAN 2 1 1980 MEMORANDUM FOR: A. Schwencer, Chief, Operating Reactors Branch #1, DOR FROM:
G. Lainas, Chief, Plant Systems Branch, DOR
SUBJECT:
FIRE PROTECTION REVIEW -
H.B. ROBINSON, UNIT 2 Facility:
H.B. Robinson, Unit 2 Docket No.:
50-261 Licensee: Carolina Power and Light Company Responsible Branch:
ORB#l Project Manager: D. Neighbors Reviewing Branch:
Plant Systems Status of Review:
SER issued; Evaluation of supplement items is on-going Our evaluation of the licensee's submittals listed in Enclosure 1 is complete. The results of our evaluation are attached (Enclosures 2, 3 and 4). presents our evaluation of issues that are complete. Enclosure 3 presents our evaluation of issues for which we need additional information and indicates the information required. presents our evaluation for which the licensee's proposals are unacceptable and indicates requirements that would resolve the issue.
We request a response within 20 days if these requirements will be satisfied. Should the licensee choose not to satisfy any of these requirements, a meeting should be arranged within the same 20 days with appropriate management individuals prior to initiating an order.
Current status of the SER supplement items is summarized in Enclosure 1.
G. ainas, Chief Plant Systems Branch Division of Operating Reactors
Enclosures:
As stated
Contact:
T. Lee, X-27878 cc w/enclosures:
See page.2 JAN 2 1 1980 cc w/enclosures:
D. Eisenhut W. Gammill
- 3. Hanauer V. Benaroya R. Ferguson T. Lee P. Matthews D. Neighbors T. Wambach R. Hall.(BNL)
E. MacDougall (BNL)
J. Klevan (Consultant)
ENCLOSURE 1 H. B. ROBINSON, UNIT 2 - FIRE PROTECTION SER SUPPLEMENT LIST OF SUBMITTALS AND STATUS OF THE ASSOCIATED ISSUES SER Section Subject Issue Submittal Status 3.1.2 Fire Detectors 04/28/78, 04/02/79 I
3.1.4 Fire Retardant Coating 12/05/78 C
3.1.11 &
Portable Extinguishers and 3.2.4 Containment General Area 04/28/78 R
3.1.17 Insulating Pipes 06/30/78, 04/02/79 I
3.1.21 Lube Oil Shielding System 12/05/78, 04/02/79, 04/27/79 R 3.1.24 Electrical Penetration Seals 09/01/78, 04/02/79, 05/09/79 R 3.2.1 Auxiliary Shutdown System 11/17/77, 02/28/78 3.2.2 Fire Door Supervision 06/30/78 R
3.2.3 Propane Tank & Piping 06/23/77, 10/27/77, 03/30/78 R 3.2.5 Containment Cable Penetration Area 06/23/77, 09/30/77, 03/30/78 R 3.2.6 Administrative Control 11/28/77, 03/30/78 3.2.7 Fire Water Pipe Rupture 04/28/78 R
3.2.8 Fire Hose Replacement R*
3.2.9 Fire Hydrant Freeze Protection 04/28/78 R
C - Complete I -
Incomplete R -
Requirement
- - The licensee has not been notified of this position previously Staff's evaluation of these items still on-going El -
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ENCLOSURE 2 H. B. ROBINSON, UNIT 2 -
FIRE PROTECTION EVALUATION OF SUPPLEMENT ITEMS THAT ARE COMPLETE 3.1.4 Fire Retardant Cable Coating SER Section 3.1.4 indicates that fire retardant coating will be applied to cables located in 13 different fire areas of the plant.
By letter dated December 5, 1978, the licensee stated that the flame-retardant coating would be applied in accordance with manufacturer's recommendations and that the manufacturer would be consulted to determine alternate applica tion methods for situations not covered by the manufacturer's standard recommendations.
We accept the licensee's proposal.
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ENCLOSURE 3 H. B. ROBINSON, UNIT 2 -
FIRE PROTECTION EVALUATION OF SUPPLEMENT ITEMS THAT REQUIRE ADDITIONAL INFORMATION 3.1.2 Fire Detectors SER Section 3.1.2 indicates that the licensee will add automatic fire detection devices in 18 fire areas of the plant and will connect to an emergency power source those portions of the existing fire detection system not presently so supplied. The licensee has committed to confirm that detectors are appropriate for the type of combustibles likely to be found in the area in which they are installed and to furnish a report of an audit of the installation design for smoke detectors in the plant to assure that room geometry and ventilation air flow have been properly considered.
By letter dated April 28, 1978, the licensee acknowledged that:
(1) A copy of a procedure and acceptance criteria used in performing the installa tion of existing and proposed smoke detectors is not available, (2) Smoke detectors are, or will be, installed using the recommendations of NFPA 72E-1974, and its appendix A, and engineering judgement, (3) Final design of the detector system will be reviewed-by an outside fire protection specialist and inspection contractors. They will also review the currently installed smoke detectors, (4) Manufacturer's test data demonstrating the capability of ionization type fire detectors will be available in the plant's record.
By letter dated April 2, 1979, the licensee provided the number and location of fire detectors, the floor area, the ceiling height and air change in various plant areas; and the qualification of personnel who will audit the detector system design. The submittal, however, did not describe how ceiling height, size, location, and orientation of beams at the ceiling, location of ventilation air inlets and outlets, and ventilation rate were taken into consideration in the distribution and placement of the smoke detectors.
Subsequently, in the telecon held on January 16, 1980, the licensee confirmed that the experience and judgement of the contractor installing the detection system, rather than a set rule, were relied on for the installation of detectors.
NRC is currently developing acceptance criteria for detector installation.
We will address this issue when such criteria become available.
The licensee has also clarified during the January 16, 1980 telecon the meaning of his statements "cross-zoned for maximum performance" and "cross zoned for maximum coverage" that were used in the description of detector systems for Zones 3, 4, 5, 15, 17, 19 and 23. Two separate and independent trains of detection systems are provided in many plant areas. Where an automatic fire suppression system is provided the detection systems are so arranged that a signal from any one detector will initiate the fire alarm E3 -
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while two concurrent signals from detectors, one in each system, are required to actuate the suppression system. We accept this provision of cross-zoning detectors.
3.1.17 Insulation of Pipes SER Section 3.1.17 indicates that three-hour fire rated insulation will be installed on the section of the "A" diesel generator fuel supply line which is routed through the "B" diesel generator room and on the section of "B" diesel generator service water line which is routed through 'the "A" diesel generator room.
By letter dated June 30, 1978, the licensee proposed to insulate these pipe lines by hydrous calcium silicate and to provide a heavy gauge stain less steel jacket with stainless steel straps to secure and protect the insulating material. The thickness of the insulation will be estimated by a steady-state radiation heat transfer calculation assuming the insulated pipe is "seeing" 20000 F. Should the estimated insulation thickness to provide 3-hour fire rating becomes unreasonably large, the method of calculation will be refined to include the transient behavior of heat transfer.
Subsequently, by letter dated April 2, 1979, the licensee provided another submittal discussing the thermal characteristics of the insulating material.
The submittal further provided that:
(1) The insulation will be applied in two layers with staggered joints; the outer layer will be 2" thick and the inner layer 1", (2) Heat transfer for the fuel oil line was neglected because the oil will not be pumped into the room with fire, and (3) The effect of using the standard time-temperature curve rather than the actual temperature is to heighten the amount of heat transferred into the insulated pipe.
The submittal is vague with respect to the method eventually used for estimating the thickness of the insulation and provided no detail-s of the calculation. In addition, the staff is concerned that it may not be appropriate to ignore heat transfer for the fuel oil line by the assump tion that the oil will not be pumped into the room on fire. It is the capability to supply the redundant diesel in the other room (rather than the one on fire) that we are protecting.
Subsequently, in the telecon held on January 16, 1980, the licensee verified that:
(1) The decision was made to re-route the "A" diesel fuel supply line out of the "B" diesel-generator room.
(2) Heat transfer into the service water line was calculated by assuming that the insulated piping is exposed to ambient air at a steady tem perature of 20000 F. Service water temperature will be maintained below 1000 F.
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t0 At the staff's request, the licensee agreed to provide a copy of the service water line heat transfer calculation and quantitative data concern ing a possible change in thermal properties of the insulating material through the dehydration process. We will address this subject when the additional information is provided.
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ENCLOSURE 4 H. B. ROBINSON, UNIT 2 -
FIRE PROTECTION EVALUATION OF SUPPLEMENT ITEMS FOR WHICH THE LICENSEE'S PROPOSAL IS UNACCEPTABLE 3.1.11 Portable Fire Extinguishers & 3.2.4 Containment General Area SER Section 3.1.11 indicates that one 2-1/2 gallon pressurized water portable fire extinguisher will be added in the control room area and that several large pressurized water extinguishers will be provided in the containment cable penetration area.
SER Section 3.2.4 indicates that the adequacy of the fire protection in the containment general area is still under review. The licensee had proposed to install smoke detectors in the air recirculation units which serve this area and to provide large pressurized water extinguishers for manual fire suppression.
By letter dated April 28, 1978, the licensee stated that large pressurized water fire extinguishers will not be provided because UL or FM listed extinguishers of this type are not available. The licensee has stated that other existing or proposed features of the containment will provide adequate means to ensure safe shutdown in case of a fire in containment.
The large pressurized water extinguishers -ere proposed by the licensee to assure an adequate fire suppression capability inside the containment in general, and at the cable penetration area in particular. Existing portable dry chemical extinguishers have a limited range and duration of discharge which may not be adequate to suppress postulated fires in containment.
Automatic fire detection systems and flame-retardant cable coatings are proposed to detect fires and limit the growth of cable fires, but neither will suppress fires. Accordingly, we will require the licensee to install standpipes and hose stations in containment to provide manual hose coverage for fire hazards therein.
The above requirement is now included in Appendix R to 10 CFR Part 50 which became effective on We, therefore, expect that the licensee will conform to this requirement. Subject to conformance to this requirement, this item is satisfactorily resolved.
The licensee has not provided any information regarding the installation of the 2-1/2 gallon pressurized water portable fire extinguisher in the control room. We will require the licensee to verify that this extin guisher has been installed.
Installation of smoke detectors inside containment will be evaluated in Section 3.1.2 -
Fire Detectors.
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0a 3.1.21 Lube Oil Shielding System SER Section 3.1.21 indicates that a lube oil spill protection and control system has been proposed to be installed around each reactor coolant pump motor to prevent contact of lube oil with hot pump surfaces.
By letter dated December 5, 1978, the licensee proposed to design a lube oil collection system to contain spilled oil from gasket leaks or failure associated with the motor lube oil system. Drip pans and catch basins will be attached to the motor to collect spilled oil and route it to a gravity-fed reservoir at each pump.
Each reservoir will be sized to accommodate the oil contained in each motor. The submittal, however, did not describe the system in sufficient details for the staff to determine if all the potential leak points are enclosed by the proposed system and what seismic criteria the system will be designed to.
Subsequently, by letter dated April 2, 1979, the licensee stated that the design and installation of this system was being deferred pending further study of an alternate means of controlling reactor coolant pump lube oil fires.
By letter dated April 27, 1979, the licensee discussed the possi bility of requesting a deviation from his earlier commitment to install fixed fire suppression systems in lieu of the previously proposed lube oil spill collection system and that a decision would be reached by July 1, 1979.
Such request has not been received to this date.
We will require the licensee to provide, in accordance with the original commitment, the lube oil collection system which meets the following criteria:
o The proposed system shall provide a complete enclosure for all poten tial leakage points, including lift pump and piping, external oil cooler, flanged connections, drain plugs, fill points, upper and lower reservoirs, sight glasses, and overflow lines.
o During a safe shutdown earthquake, the effects of the seismic event on the system will not adversely affect plant safety.
o Strainers or other means of preventing clogging of drain piping shall be provided.
The above requirement is now included in Appendix R to 10 CFR Part 50 which became effective on We, therefore, expect that the licensee will conform to these requirements.
Subject to conformance to this requirement, this item is satisfactorily resolved.
3.1.24 Electrical Cable Penetrations SER Section 3.1.24 indicates that fire tests of the cable penetration designs used in this plant will be performed and that those which do not exhibit appropriate fire resistance will be modified or replaced by accept
-able tested designs.
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By letter dated September 1, 1978, the licensee provided the results of the fire resistance tests of cable tray and conduit pentrations. The licensee stated that certain of the tested designs were representative of those at the plant and that the tests demonstrated that these designs had 3-hour fire resistance ratings.
Conduct of the tests was in substantial agreement with the criteria pre scribed by the staff except for three items:
o The conduit penetrations were not symmetrical and were not tested from both sides.
o The hose stream test of the wall slab was conducted while using a spray nozzle set at an angle of 50 degrees while IEEE 634-1978 calls for a 30 degree included angle.
o A hose steam test was not performed on the floor penetration test slab.
o A positive differential pressure was not applied across the penetra tion during the fire test.
The staff has also requested the licensee over the telephone to clarify:
o The density of ceramic fire insulation used in the penetration seals, o
The type and percent fill of caoles used in the test, o
The size of conduit seals in the plant conpare with those tested.
By letter dated April 2, 1979, the licensee responded to the staff's concerns regarding the hose stream test for the penetration seals by comparing the construction of their penetration seal with one which had successfully passed a hose stream test.
By letter dated May 9, 1979, the licensee reported that conduit penetrations through fire barriers would contain a 9-inch thickness of silicone foam instead of the previously tested 12 inches.
The licensee cited manufacturer's test data to support the reduction in foam depth.
We accept.the licensee's conclusions on the hose stream test and on the reduction in the thickness of silicone foam. The licensee, however, has not addressed other staff concerns listed above. We will require the licensee to provide additional information as identified below:
(1) The results of tests or analyses that will establish the effects, on the fire rating of penetration seals, of the maximum pressure differen tial a fire barrier in the plant is expected to experience.
(2)
The results of tests or analyses that can establish the fire rating of asymmetric penetration seals in the untested direction.
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(3) The density of ceramic fire insulation, the type and percent fill of cables and the size of conduits used in the test as compared with those in the plant to demonstrate that the test arrangement is repre sentative of the worst case configuration existing in the plant.
All of the above requirements are now included in Appendix R to 10 CFR Part 50 which became effective on We, therefore, expect that the licensee will conform to these requirements. Subject to conformance to these requirements, these items are satisfactorily resolved.
3.2.2 Fire Door Supervision SER Section 3.2.2 indicates that, following the completion of the physical security evaluation, any remaining non-supervised fire doors protecting safety-related areas will be identified and a method proposed for assuring these doors remain closed.
By letter dated June 30, 1978, the licensee provided a set of marked-up drawings identifying all fire doors and indicating which would be locked and/or electrically supervised, and which would not be.
The licensee's submittal, however, d'd not include any justification of the decision not to supervise those Fire doors which are neither locked nor alarmed. Specifically, the licensee did not describe the hazards (including combustibles and safety-related equipment or cabling) on both sides of each fire door that are not supervised and the safety consequences of a fire communicating through these open ooor.ays.
The licensee is required to conform to the following position:
Fire doors shall be self-closing or provided with closing mechanisms, and shall be inspected semi-annually to verify that automatic hold-open, release, and closing mechanisms and latches are operable.
One of the following measures shall also be provide:
(1) Fire doors shall be kept closed and electrically supervised at a continuously manned location; or (2) Fire doors shall be locked closed and inspected weekly to verify that the doors are in the closed position; or (3) Fire doors shall be provided with automatic hold-open and release mechanisms and inspected daily to verify that doorways are free of obstructions; or (4) Fire doors shall be kept closed and inspected daily to verify that they are in the closed position.
The fire brigade commander shall have ready access to keys for any locked
- fire doors.
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Areas protected by automatic total flooding, gas suppression systems shall have electrically supervised self-closing fire doors.
'All of the above requirements are now included in Appendix R to 10 CFR Part 50 which became effective on We, therefore, expect that the lkensee will conform to these requirements. Subject to confor mance to thse requirements, these items are satisfactorily resolved.
3.2.3 Propane Tank and Piping SER Section 3.2.3 indicates that the licensee would provide an analysis of the fire hazard associated with the propane tank supplying the propane engine-driven fire pump.
By letter dated June 23, 1977, the licensee discussed the consequences of a postulated BLEVE (Boiling Liquid Expanding Vapor Explosion) of the 500-gallonpropane storage tank.
The licensee estimated that the shock wave resulting from tank rupture would decay to less than 1 psig at about 40 feet ifr the tank and that the fireball would release energy at a rate sufficientto ignite wood at 66 feet and last nearly 10 seconds.
The
'licensee concluded that these effects presented no hazard to safety-related equipment at the intake structure.
By letter tated October 27, 1977, the licensee discussed the consequences of a break in the fuel supply line from the propane storage tank to the fire pump engine. Two scenarios were considered:
immediate ignition of
,the leakig propane and delayed ignition.
The licensee concluded that in
,case of !mediate ignition, the missile shield on the intake structure and the distaice between safety-related pumps and the postulated fire would preclude significant damage to safety-related equipment on the intake structme-., The licensee further concluded that in the case of a delayed ignitilonof the vapor cloud a deflagration, rather than a detonation, would occww.
The licensee cited three technical articles which claimed that detonation of unconfined propane-air vapor clouds is not possible, and stated that the modest overpressures due to a deflagration would not damage the safety-related pumps.
However, the licensee proposed to install an automatic fuel shut-off valve at the propane storage tank connection to the fuel so-ply line in accordance with the requirements of NFPA 37 and
- 58.
By letter dated March 30, 1978, the licensee reiterated his contention that detonation of a propane-air mixture was not possible and also revised
-earlier estimates of the overpressure produced during a postulated BLEVE.
The licensee concluded that the peak pressures of 1 to 1-1/2 psig produced by a BLEVE or a vapor cloud deflagration would not damage safety-related pumps or piping because the U.S.
Department of the Interior has stated that at least 12 psig is necessary to cause such damage.
The licensee further argued that the 50-foot separation between the tank and the safety-related pumps and piping was adequate because it exceeded the 10-foot minimum separation between above-ground tanks of this size and
- important buildings specified in NFPA 58.
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The staff does not agree with the licensee's contention
-he arrangement of the propane storage tank and other equipment is satisfact; y in relation to safety-related equipment on the intake structure for the f 1lowing reasons:
(1) Although detonation of an unconfined propane-air cloud may be difficult, it is not impossible. Accidental and experimental detonations of propane-air vapor clouds have been reported by Strehlow and Baker
("The Characterization and Evaluation of Accidental Explosions," NASA report CR-134779, June, 1975), Lee et al.
("Blast Effects from Vapor Cloud Explosions," presented at the 1977 AIChE Loss Prevention Symposium, March, 1977, Houston, Texas), and others.
Lee et al. reports that Kogarko et al. (International Chemical Engineering, Volume 6, No. 3, page 93, 1966) found pressures of 0.5 atmosphere at distances of about five times the vapor cloud radius in detonations of spherical stoichiometric propane-air mixtures.
(2) Confinement of the propane-air vapor cloud by the missilc shields and other barriers on the intake structure could alter signi icantly the severity of damage produced by ignition of the vapor clo.
(3) The licensee has not provided the basis for concluding t at the indicated peaked pressures and fireballs will not damage any safety related equipment on the intake structure. No details.
provided regarding the applicability of the U.S. Department of t Interior 12 psig damage limit to this situation.
(4) The 500-gallon propane storage tank probably represents ie least amount of propane which must be considered in the ana
- z. Refilling the tank from time to time will introduce the additio hazard of a much larger quantity of propane carried on the tank t
, plus the hazard of transferring the propane to the storage tank (5) It is doubtful that the special needs of nuclear power r. ants were considered in the separation distances specified in NFPA 58.
(6) Damage to equipment other than pumps and piping, such as wiring and control equipment, may be sifficient to impair the operability of safety-related pumps on the intake structure.
Therefore, we will require the licensee to:
o Replace the propane engine with a diesel engine, or o
Relocate the propane engine-driven fire pump and associated equipment to a location substantially remote from any safety-related equipment.
3.2.5 Containment Pentration Area (Inside Containment)
Section 3.2.5 of the fire protection SER indicates that the adequacy of
- fire protection in the containment.penetration area is still under review.
This area contains redundant cables required for safe shutdown.
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During the preliminary evaluation of fire protection in this area, we requested additional protection (automatic water fire suppression capabil ity and/or separation by barrier) be provided for this area. The licensee contended that fire protection in this area is adequate as is and indicated that additional information will be submitted to substantiate his conclusion.
By letter dated June 23, 1977, the licensee stated that there is no existing pipe penetration available for bringing fire water into the containment.
It was proposed that a fire in this area will be fought using portable extinguishers with backup hose line from outside the containment.
By letter dated September 30, 1977, the licensee reiterated the lack of the pipe penetration and stated that introduction of fresh water into the containment would risk potential boron dilution in the event of LOCA. The submittal further stated that cabling in the area is silicone rubber insulated and jacketed; such cables have been shown by tests to be capable of maintaining circuit operability even after it burned.
By letter dated March 30, 1978, the licensee provided sketches and photo graphs of the area. However, no dimensions were provided on the sketches.
The licensee has never quantified the spatial separation nor the "sphere of influence" mentioned in their fire hazards analysis.
They did not provide any results of tests or analyses to support their conclusion that fire protection in this area is adequate. As was discussed in the evalua tion of Section 3.1.11 above, portable extinguishers have only a limited range and duration of discharge so that they are unlikely to provide adequate capability to suppress a large fire in this area.
While the tests cited by the licensee showed that leakage current, from a silicone rubber cable exposed to fire, can be limited to less than one (1) ampere they did not demonstrate that a (fire) damaged silicone rubber cable can indeed perform the safe shutdown function required of it under a real fire condition.
As to the risk for boron dilution, NRC guidelines explicitly discount the possibility of a fire taking place concurrent with the LOCA. In addition, the fire water flow rate out of an interior manual hose is in the order of 200-500 gpm, and most fires can be extinguished in about 15 minutes.
The refueling water storage tank contains approximately one quarter of a million gallons of water borated to a concentration that has several folded safety margins for maintaining the reactor subcritical.
The concern for the risk of boron dilution is, therefore, unfounded.
We conclude that the licensee to date has not provided reasonable assurance that a fire in this area will not involve redundant cables required for safe shutdown.
We will require the licensee to provide additional protection (automatic fire suppression and/or barrier separation) to preserve the safe shutdown capability and to provide the capability for suppressing fire.
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Al1 of the above requirements are now included in Appendix R to 10 CFR Part 50 which became effective on We, therefore, expect that the licensee will conform to these requirements. Subject to confor mance to these requirements, this item is satisfactorily resolved.
3.2.7 Fire Water 'ipe Rupture
'The fire protection SER, Section 3.2.7, indicates that our evaluation of the effect of rupture of fire water system piping on safety-related system or component has not been completed.
By letter dated April 28, 1978, the licensee contended that fire protection piping inside safety-related areas in H. B. Robinson, Unit 2 facility meets Class I seismic criteria; thus Paragraph B.3.d of Branch Technical Position APCSB 3-1 is not applicable.
Consequently, the licensee provided no analysis for the subject issue.
'General Design Criterion 3 in Appendix A to 10 CFR 50 requires, among other things, that firefighting systems be designed to assure that their rupture or inadvertent operation does not impair the capability of
,safety-related structures, systems, and components.
We will require the licensee to provide the results of analyses to demonstrate that fire protection systems in H. B. Robinson facility meet such requirement.
3.2.8 Fire Hose Rplacement SER Section 3.2.8 indicates that the staff evaluation of the type of fire hose -needed for replacement and new installation has not been completed.
During tht" plant site visit, some linen hoses were observed to have mildew on.
Becamse mildew would cause degeneration of linen hoses rendering them less rel.idAnle, hoses made of other materials less susceptive to such problem are desirable.
We will require the licensee to replace the existing linen hoses, when they are due for replacement, by mildew-proof, heat resistant, ".00% polyester single jacket, synthetic rubber. lined hoses rated no less than 300 psi by FM/UL label.
3.2.9 Fire Hydrant Cold Weather Protection SER Section 3.2.9 indicates that the staff has not completed its evaluation of the adequacy of licensee programs intended to assure proper functioning of outside hydrants.
By letter dated April 28, 1978, the licensee indicated that hydrants would be inspected once a year, in the fall.
The licensee has declined to make a spring inspection of hydrants on the basis that none have been damaged by freezing in 18 years at the plant.
Nevertheless, the staff considers that a spring inspection should be a part of a prudent hydrant maintenance program because both NFPA 22-1978 and FM Data Sheets, No. 3-2, December 1977, indicate that the plant site is within the region of freezing weather.
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We will require the licensee to perform semiannual inspections of outside hydrants.
The above requirement is now included in Appendix R to 10 CFR Part 50 which became effective on We, therefore, expect that the licensee will conform to this requirement. Subject to conformance to this requirement, this item is satisfactorily resolved.
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