ML14190A546
| ML14190A546 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 02/06/1980 |
| From: | Schwencer A Office of Nuclear Reactor Regulation |
| To: | Jackie Jones Carolina Power & Light Co |
| References | |
| NUDOCS 8003100216 | |
| Download: ML14190A546 (18) | |
Text
EbATO Y OCKET fILETC Y File NSC WGammill CParrish NRCPD QRB#1 Rdg TJCarter OELD L PDR DEisenhut WRussell ACRS (16)
TERA RVollmer BGrimes IE (3)
Docket No. 50-261 LShao JHeltemes-AEOD JRMillef-Gray'File ASchwencer DNeighbors Mr. J. A. Jones TWambach Senior Executive Vice President.
Carolina Power and Light Company 336 Fayetteville Street Raleigh, North Carolina 27602
Dear Mr. Jones:
We have been reviewing your submittals related to the Nl B.-Robinson Steam Electric Power Plant, Unit No. 2 Fire Protection Program.
These sub mittals are listed with their stats u
n nclosure 1.
The results of our evaluatlinare g ached as Enclosures 2, 3 and 4. presents our evaluation f issues that are complete.
Enclo sure 3 presents our evaluation of issues for which we need additional information. Enclosure 4 presents our evaluation of those issues which we find-not acceptable and in icatesrequirements that would resolve the issue.
We request that you respond within 20 days of the date of receipt of this letter. If you do not plan to meet these requirements, you should request a meeting within the same 20 ays.
Sincerely, A. Schwencer, Chief Operating Reactors Branch #1 Division of Operating Reactors
Enclosures:
- 1. List of Submittals & Status
- 2. Evaluation of Supplement ems (Complete)
- 3. Evaluation of Supplement Items (Require Additional In )
- 4. Evaluation of Supplement Ttems (Unacceptable) cc w/enclosures:
See next page OFFICEk ORB#1:DOR ORB#2:DOR ORB# 1:
.~RU~
UN/c r
SURNAME
- .a
.ASch a cer bATE 2/(0/80 8.003 1.00_2-1_
NRC FORM 318 (9-76) NRCM 020 J S GOVEPN-ENT DRINTING OFFICE: 1979-289-369
-2 r.. A.
ones Carf-a Pwer and Light Company cc:
G. F. Trowbridge, Escuire S-aw, Pittman, Potts and Trowbridge 10 ZO.
,Street, N.W.
W=shington, D. C. 20036 Hartsyille Memorial Library H=re and Fifth Avenues Ear-srille, South Carolina 29550
.iciael C. Farrar, Chairman A:moic Safety and Licensing Apeal Board Panel U. S. Nuclear Regulatory Commission
- shidgton, D. C. 20555 ch-ia-d S. Salzman A:Mci: Safety and Licensing kIApeal Board Panel S. Nuclear Regulatory Commission Vashington, D. C. 20555 W. Reed Johnson oi: Safety and Licensing Ar:.al Board Panel
.Nuclear Regula:ory Commission o.D. C. 2 5 55
ENCLOSURE 1 F. S. ROBINSON, UNIT 2 - FIRE PROT TION SER S2PPLEMENT LIST OF SUBMITTALS AND STATUS OF TiE 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, C4/02/79, 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, 02/28/73 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 06/2^/77, 09/30/77, 03/30/78 R 7 3.2.6 Administrative Control 11/2877, 03/30/18 1
3.2.7 Fire Water Pipe Rupture C4/28/78 R
3.2.8 Fire Hose Replacement 3.2.9 Fire Hydrant Freeze Protection C4/28/78 R
C - Coea I
- Ino :e:e R -
Re:
~
- ne-is-e has not been n.tified of this :Cs :ion previous v
- ---------valuaion of these items still on-c:
ENCLOSURE 2 E B. ROBINS0.
UNIT 2 - FI 0
"Tc EVAULATION OF SUPP'LE&NT ITE Tr -T ARE 3.1.4
- Fire Retadast Cable Coatino S
Section 11.4 indicates that fire retardant coating will be applied to cableS catal in 13 different fire. areas of the plant.
By outtlrda ed Dece ier 5n 1978, the licensee stated that the flame-retardant coating ouldbe applied in accordance with manufacturer's recommendations and that the mnufacturer would be consulted to determine alternate applica tion methods for situations not covered by the manufacturer s standard reccept his e
o We acet the licensee's proposal.
ENCLOSURE 3 H. B. ROBINSVN. UNIT 2 -
FIRE PROTECTION EVALUATTCN OF SUPPLEMENT ITEMS THAT REQUIRE ADDITIONAL INFORMATION 3.12 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-19074, and its appendix A, and engineering judgement, (3) Final design of the cetector system will be reviewed by an outside fire protection s:ecialist and inspection contractors.
They will also review the currently ins.ailed sroke detectors, (4) Manufacturer's test data demonstrating the cEDE:l-t% cf ionization.type fire detectors will be available in the plat s reecrd.
By ieter dated April 2, L79, the licensee provided the number and location cf -ire detectors, the flocr area, the ceiling height and air change in var cs D.a-: areas; and the qualification of personnel who will audit the t -sem desion.
The submittal, however, did not describe how cei height, size, location, and orientation of beams at the ceiling, lC:.-
c, ven:iiatior ai inlets and outlets, anc ventilation rate were take-4-.c :onsideratic7 in the distribution and placement of the smoke Sin the tEle~n held on January 16, 1980, the licensee confirmed
- x~erie n
gement of the contractor installing the detection syss-e-ratner than a set rule, were relied on for the installation of N'
crSenly evelco hn: acceptance criteria for detector installation.
w a.
c-ess this issue when such criteria become available.
ienas alsc :iarfied during the January 1,. 1980 telecon the t -cross-Zoned for maximum Derformance" and "cross
- ove-ae, that were used-in the cescription of detector cnes 4.
- 17.
19 and 23.
Two separate and independent
- =e::ior *svs.s are povided in many plant areas. Where an
-up-re:
system is provided the cetection systems are so E Sign.
any one detector will ihitiate tne fire alarm
whie two concurrent signals from detectors, one in each reaLired to actuate the suppression system. Weaccept this provision of cross-zoning detectors..
.7 Insulation of Pipes SER Section 3.1.17 indicates that three-hour fire rated insulation will be irstalled on the section of the "A' diesel generator fuel supply line which is routed through the uB" diesel generator room and on the section of "" diesel generator service water line which is routed through the UA" 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" 20000F. Should the estimated insulation thickness to provide 3-hour fire rating become unreasonably large, the method.of calculation will be refined to include the transient behavior of heat trarnsfer.
Sabsecuently, by letter dated April 2, 1979, the licensee provided another submittal discussing the tiermal cnara:teristics of the insulating material.
The submittal further provided tha::
(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 transfe-for the fuel oil line was neglected because the oil will not be purped into the room with fire, a (3) The efe::t cf using the standard time-:emperature curve. rather than the actual temperature is to heighten the amoun: of heat transferred into the insulated iis vague wtnrespe:: :: the method eventually used for 7Enc the thickness cf the insulation and provided no details of the atin.
In addition. tne s a7 is concerned :Mat it may not be
-~e to ignore neat t as'Es
- - -ne fuel cil line by the assue.D C-nat the oil wilY not be :be
- ez itc trne room on fire.
7t is the came~ 11y to supply the redun:ant c:ese in the other room (rather than
- nae on fire) that we are prcs
- E::-'r secuently, in the telecon helc :n january 16, 1980, the licensee verified T)
J-cEcision was made t "e-r:U:e the "A" diesel fuel supply line cut "B" diesel-oenerat.....
. ansfer in to
- serviae wa:e-line was calculated by assumr,:
- nat Cne insulated c:ing is exz:se to ambient air at a sead' zer
- -:: e of 20000-.
Service
-as
- enerature will be maintaine
- eow 100oF.
At the staff's request, the 1icensee agreed to provide a copy of th service water line heat transfer calculation and quantitative data concert ing a possible change in thermal properties of the insulating material through the dehydration process. We will address this subject wher. te additional information is provided.
ENCLOSURE 4 H. S. ROBINSON. UNIT 2 -
FIRE PROTECTICN Ai'T;oN OF SUPPLEMENT ITEMS FOR WHICH THE LICENSEE'S PROPOSAL IS UNACCEPTABLE 3.1.11 por-le Fire Extinguishers & 3.2.4 Containment General Area SER Secion 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 contajnment 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 propcsed to install smoke detectors in the air recirculation units which serve ttis area and to proyide large pressurized water extinguishers for manua fire suppression.
By leztr dated April 28, 1978, the licensee stated that large pressurized wate, -.-e extinguishers will not be provided because UL or FM listed extzrgu4.sners of this type are not available. The licensee has stated that cther existing or proposed features of the containment will provide adequate means to ensure safe shutdown in case of a fire in containment.
The e
Dressurized water extinguishers were prcposed by the licensee to ass.-= an acequate fire suppression capability inside the cor-linment in genera.. anc at the cable penetration area in particular. Existing portable dC7 'ei extinguishers have.a limited range and duration of discharge n7
. n: De adequate to suppress postulated fires in containment.
-i-e detection systems and flame-retardan-. cable coatings are Ce.ca t fires an!d limit the growth of cazie 'ires, but neither W
-,ss ires.
Accordingly, we will require the Ticensee to install a -c nose s ta:ions in containment to provide manual hose coverage c-
---a-ds therein.
In~asaion of smoke oaetectors inside containment will be evaluated in Se=.-
.>3 - Fire Detectors.
- 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 put 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 fro-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 systen which meets the following criteria:
0 The proposed system shall provice a complete enclosure for all poter tial leakage points, including 7ift pump and piping, external oil cooler, flanged connections, rai.
cS, fill points, upper an+/-
lower reservoirs, sight glasses. an: overrlow lines.
o During a safe shutdown eartho:a.<. t e ec ts of the seismic event on the system will not advers: aff: plant safety.
o Strainers or other means of preventing clogging of drain piping shall be provided.
3.1.24 Electrical Cable Penetrations SER Section 3.1.24 indicates that fie tests cf the cable penetration designs used in this plant will b:; Derformed and that those which do not exhibit appropriate fire resistan:_.i; b= modified or replaced by acce:t able tested designs.
-E4 2-
By letter dated September 1, 1978, the 1i:ensee provided the results of the fire resistance tests of cable tray anc conduit pentrations. The licensee stated that certain of the tested :esigns were representati-.e of those.at the plant and that the tests der:nstrated that these designs hAA 3-hour fire resistance ratings.
Conduct of the tests was in substantial agreement with the criteria pre scribed by the staff except for three itens:
o The conduit penetrations were not svyretrical and were not tested from both sides.
o The hose stream test of the wall slas was conducted while using a spray.nozzle set at an angle of 50 cagrees while IEEE 634-1978 calls for a 30 degree included angle.
o A hose stream test vas not performed on the floor penetration test slab.
o A positive differential pressure was not applied across -ne penetra tion during the fire test.
The staff has also requested the licensee over the telephone to clarify:
o The density of ceramic fire insulatior. used in the penetration seals,
.0 The type and percent fill of canles use in the test, o
The size of conduit seals in :he 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 b-.
comparing the construction of thei- :enetra:ion seal with one wrin na:,
successfully passed a hose stream :est.
By letter dated May 9, 1979, tie Iensee re:crted that condoL: Den:a ons through fire barriers woujl contai a -
.nickness of s7il::ne instead of the previously tested 12 inhes. The licensee cits: mana: -rer s test data to support the redu::ior foz.- :=otn.
.We accept the licensee's con:clusions on :18 nose stream test an: on :he reduction in the thickness of silicone fcaz.
The licensee, hcwever, has not addressed other staff concerns
- stec aove.
We will reqire t-e licensee to provide additional informatic. as identified below:
(1)
The results of tests or analy-es tha w1l establish the effe::s.C the fire rating of penetratic Seais, : he maximum pressure :
-i tial a fire barrier in the plan-is ex:ected to experience.
(2) The results of tests or ananiLes :E:cn establish the fire ratin:
of asymmetric penetraticn se5 i :-e est ested directio.
(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.
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, did 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 nazards (including combustibles and safety-related equipment or cablirg) on both sides of each fire door that are not supervised and the safet consequences of a fire communicating through these open doorways.
The licensee is required to confore 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 hole-open, release, and closing mechanisms an:.atches are operable.
One of the following measures shal' also be provide:
Ire doors shall be kept close: ad le:trica. : suoerv-a continuously manne locatio-; :
(2) ire doors shall be locked cl:sed and insoected weekly t: veri v that
- ne doors are in the closed p:s'tion; c
(^) Fire doors shall be provided &:r automatic hold-open an: re-ease mechanisms and inspected daily :o verify that doorways are free cf obstructions; or (4)
Fire doors shall be kept closed and inspected daily to verify that they are in the closed position.
ine i e brigade commander shall have "eady access to keys for any 0CKe:
Areas protected by automatic total flooding, gas suppression systems shall have electrically supervised self-closing fire doors.
.3 Propane Tank and Piping SER Sectionz3.2.3 indicates that the licensee would provide an analysis Cf the fire hazard associated with the propane 'tank supplyinthpraz engine-driven fire pump.
ng the ropae By letter dated June 23, 1977,-the licensee discussed the consequences of a Postulated BLEVE (Boiling Liquid Exanding Vapor Explosion) of the 5 0 0-gallon propane storage tank.
The licensee estimated that-the shock.
wave resulting from tank rupture would decay to less than psig at about 40 feet from the tank and that the fireball would release energy at a rate sufficient to ignite wood at 66 feet and last nearly 10 secons aTh licensee concluded that these effects presented no hazard s-reaed equipment at the intake structure.
By letter dated October 27, 197, the licensee ussed the consecLences of a break in the fuel supply line fom the re tohrage tak to :ne fire pump engine. Two scenarios were consiered:
immediate igni tio
-f the leaking propane and delayed ignizion.
Tne licensee concitLed :ha: i case of immediate ignition, the missie shield on he intake truch-e ar, the distance between safety-related sumps and the postulated fire woula preclude significant damage to safe:prelated equipment on the intake structure.
The licensee further ccncluded that in the case of a delayed ignition of the vapor cloud a deflaaation rather than a detonatioly would occur.
The 1icensee cited tree techncal articles which Cdaietn e
that detonation of unconfined Dropae-it vaticr clouds is not
- lossibed, ano stated that the modest ove!ea.
vae c lod sno0 ! WoUibl e damage the safety-related pumpes.
ao-ver. tc e lo a enseE prooweoul s
En automatic fuel shut-offi e
Val%-icensee prao D-Zne ';Ueli supply line in a:oa~w-trie
-e: 7 e-rnS Of
~
By letter dated March 30. 97:, -his that detonation of a propane-a'
-e :tessible and
=_
rC."
earlier estimates of the overpress-_
siroDc~e:
a eC
.Z 5D The licensee concluded that t-e ;e.c<
ress uareso a stu a so by a BLEVE or a vapor clout deiaoa'jcn wo1e sse not damage safetv-re ea c
pumps or piping because the U.S. D n
ar wuen of the Interior has stated that at least 12 psig is necessary en cause such anage.
The licensee further argued that the 50-foo seauation beween the tank and the safety-related pumps and piping azeiuae because it exceeded the 10-foot minimum separation betwee.
-: e-c becuse t
tnks of this s1e im-ortant buildings specified e
1 s1 V'
es rot agree with the licensee's contention that the arrangement c2
)
- ae storage tank and other equipment is satisfactory in relation safe--y-reiated equipmen on the intake structure for the fol lowIng (2) g detonation of an unconfined propane-air cloud may be dffdul a ns
- e.
Accidental and experimenta c
detonations of vapor clouds have been reported by Strehow and Baker Saracte riz atiorn and Evaluation of Accidental Explosions," NASA CR-U34779, June, 1975), Lee et al.
("Blast Effects from Vapor d Explosions, presented at the 1977 AIChE Loss Prevention ymposium, 197, Houston, Texas), and others.
Lee et al. reports that Koaz-k et al. (International Chemical Engineering,. Volume6, No. 3, 066) found pressuresof 0.5 atmosphere at distances of z ive times the vapor cloud radius in detonations of spherical e
oansit-ltdqimpropane-air mixtures.
(2) =v-F=.nemen of the propane-air vapor cloud by the missile shields and.
S!a-,.iers on the intake structure could alter significantly the sere iv of damage produced by ignition of the vapor cloL-d.
(3) 7h=_ fznsee has no: provided tebssfrconcludingtath a -.s t
h bai Sor iniae that theayo nzi~ed peaked pressures and fireballs will not damage any safety
-e:
equipment on the intake structure.
No details are provided S'n he applica-ility of the U.S.. Depar-een: of the Interior 12 z :age limit to :his situation.
EX-allcn propane storage tank probably re~resents
.)e least roane wt'ich -must be considered in the analysis.
Refilling sro=
time 'to tim.e will introduce the additional hazard. of a
=--~e cuantt ff Proaecrido the tank truci, plus h
r-ansferl-n: thz-prooane to -he s-o-age tank.
_::ul that
)esecia nedDfnula ower plants were S:be seU.-o6dsances s:)eci f"e:_ Th NFPA 5E.
-:c-
- rr o:e e than Pumps and piDi-,-. such as ft'iring and
-e
~.kce--z. ma:. ze si fficien-. to iMpa'- -n-- opera:-ility of Etc :uf:)z
- ,ne ln-ake struc,.ure.
i,_-Il require telicensee to:
C:-ie propane en EWti a diesel encine, or
-.~.ni en fire Pupur.
anc Essocia:ed equipment
- :::~o-S
~
- a.
re,-zt,?e fror En% s:,;e:'.-re lated eupet e
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R n t'i at s
!, a the ate u
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- .=
Eene -ra o7-a-c--
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F ZL*
During the prelimind evaluation of fire protection 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 ticn 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 l; ampere they did not demonstrate that a (fire) damaged silicone rubber a:le can indeed perform the safe shutdown function required of it under a e=
,ire condition.
As tc tne risk for boron. eilution. NRC guidelines explicitly discount tne
- -zlt of a fire 1-ta~n 7)ene exlctlei ss tir yof' a fire takin olace concurrent with the LOCA.
In acdition r:a f
-water flow -ae cut c an interior manual hose is in the coer of 3Cu cn, and most fires can be extincuished in about l5 minutes.
Tne
.efuelinc water storage tank.contains approximately one quarter of a mi.lion callons of water borated to a concentration that has several folded safety margins for maintaining the reactor subcritical.
The concern for the possibility of introducing a large quantity of fresh water into the containment due to rupture of fire water piping can be alleviated by providing a fire water shutoff valve at the oersonnel access lock outside the containment that allows
-he fire fi:hter to charge the fire water system prior to entering in cntaiment. The concern for the risk of boron dilution is, h~e-a: e.,nfoinded.
v cE ConCaude ha the licensee to cate has not provided reasonable assur nce re in this area wi not involve redundant cables requirec for rez:re the licensee to p-cvoeadditional protection (aut =
sic and/.- carrier s-cartion to preserve the safe Sac n and -o prcvice the caza:
For suppressing fii re.
3.2.6 A rlsrative Controls -
Evaluation of Incomplete Items Our initial SER indicates that the licensee's description of their Prwtose adinistrativf controls was being reviewed for conformance Vit! CU.'delines set forth in "Nuclear Plant Fire Protection Functional Resmo'sibilities. Administrative Controls and Quality Assurance.tn BY eunt of November 28, 1977, the licensee described these controls in a od0cU1,M entitled "Adeinistrative Controls for Fire Protection."
addt 1olelt the licensee our requests for Bydtiorae infomation and commitments relative to this description.
BY letter dated March 30, 1978, the licensee responded to our requests.
We ave evaluated these sunittals, and the information. obtained frc: u-consultants, and find that t e licensee complies with our assns:native guidelines except for our concerns about: the assic
-ne of Shift Supervisors as Fire Brigade Leaders; fire brieoe Physical examinations requirements; fire brigade training; rev-ole t work requests for special fire protection requirements; conrthl to be used for untreated wood; basic radiation training for te fsite fie deparnent personnel, and various provisions of hew ir Potcton's Quality Assurance Program. These concerns and t!,rr evaluations and resolutions are as described herein.
d.E=ri:ens noted in the licensee's, administrative controls ces:1:w:icn and their evaluation and required resolutions are n;
the licensee's administrative controls descriptions
- t-describe the fire brigade's composition, our August o
77 consultant s report indicated that the Shift v
are assigned as Fire Brigade Leaders.
We evio evaluated this situation, and find that it does n: ataly with the provisions of our guidelines, nor c
on tabished staft Dosition on this matter. This onlstates that, the Shift Supervisor's respon
-" lfties for the overall operation and plant safety e
conflict with the responsibilities of an on-the 1s ol-re Brigade Leader during a fire emergency."
'-z thso not bncer, we will require that the Shift nicadmeber of the fire brigade and the T ic Ade Leade's cw:ies be assigned to trained and
- a-ied individuals wnc have a reactor operating license.
- E4 2.
e 7 teinsee indicated that drills are:-
presently performed at E-=,ozth intervals and involve the entire plant force;.(2) in til-future, however, shift drills wouldbeeroeda inte'-als to average one drill every three months; (3) these drills aill normally be performed on the back shifts; (4) all e-anral drills are unannounced in order to better assess Personn.~el response to a spontaneous situation.' We have evaiuated this response, and find it does not comply wtth Provisicn.s of our -guidelines and is, therefore,, not acceptable.
To resolve this concern, we will require the licensee to commit to perform fire drills at regular inter als, but not to exceed 3 months for "each" fire brioade. At least one drill per year should be performed on a 'bask shift" for each fire brigade.
The licensee indicated that o requets involving pla-t equipmi&ent or systems are reviewed by the dt hf forer who authorizes the work soned pois revw ndi to assess the i atiouse erfont edl Thienso Sre Isfo Fir s
Prtetio of the work on plant operation and safety - it is not totally concerned with fire protection Also, where any question arises regarding additional f re prctection measures the responsible engineer may be consulte We have evaluated this information, and find it toes not fully satisfy the provisions of our guideines and. therefore, is not acceptable. To resolvelthe concern, v17 require that all work requests involving plant s-se!s in, sa f sety-related areas should be reviewed for ire * )-.tection impact by the Plant Fire Chief or an equally 0.. 'ficd individual.
This review should also assure the nclusionl of fire protection requirement including ionit-ion sources and combustiles and provisions rovfire suroression capabilit T-. --
m Vensee did not address various essential elements of rc_,r 7::
- -2 n t 6 guidelines, in their Quality Assurance P-o:.
r Fire Prot~ection, such as:
a *ese of applicable guidelines of Reulatory Guide as specified in Section 1.0, Attachment 6; b)
-eview of design and related documents as noted tn Section 1.0 a, b,.and c, Attachment 6; c, crilsions to assure that a&-inistrative controls' e-.-entary procectues and ins'-'u:tions are reviewed
~iedin Se:tj64on 2.0 c of Attachment 6; ios 0 assuLre that the appIi cat ion of fire
-C:a: czatincs is performed bv trained personnel E ;aroved Pnocedures; and
~oac faudits on an annial basis, which naaectic-reieo.
= core:c deficiencies, as T~ na erne re~ ie~ sAttachment 6.
To Judge the licensee's Fire Protection Quality Assurance Program as acceotable, we will require the licensee to cormit to comply with t-he. Attae-,ent 6 guidelines. elements discussed above.
By letter dated March 13, 1978, we requested the licensee to commit
- 1. provide at least annually, practice sessions in actual fire extincuishnent using equipment similar to that which would be used in the plant, with a portion of the practice to include the use of breathing apparatus under strenuous conditions;
- 2.
hold regular planned meetings every three months, which will repeat the fire brigade members classroom instruction within a two year period;
- 3. offer training to their offsite fire department personnel in basic radiation hazards and precautions to be taken in a fire involving radioactive materials in the plant; and
- 4. establish administrative controls to require that all wood used in safety related areas is treated with a flame retardant comertially accepted material, suitable for such applications.
We have evaluated the licensee's March 30, 1978 responses to the a;ole fcjr requests and find that they are all unacceptable.
The icensee has either not provided a commitment to comply, or provided a~ce.ta6ie equivalent alternatives to any of the above guidelines.
IC rsolve tiese concerns, we will require the licensee to commit S:r.-n.v v'ih the provisions of our guidelines noted above.
These p-vtaisns a e cnsidered essential elements for acceptable adminis tra-.ive cntrols for fire protection.
v tn~e licensee's administrative controls description dated November r,
a t he March 30, 1978 letter, the licensee provided in stiac relative to the fire brigade's physical examinations.
Or revie. indicates that these examinations are not provided arna liY, nc-designed to determine whether brigade members are c
perforning under strenuous fire fighting activities, arid are, toerefore, not acceptable. To resolve our concern, we wl. req i-e the licensee to provide a commitment that the fire b-igde esers' qjualification shall include an annual physical ex:na-i: :- for performing strenuous fire fighting activity.
3.2.7 Fir 'Wate Moe Ruoture The fZ-e prtection SER, Section 3.2.7, indicates that our evaluation of the effec: of rupture of fire water system piping on safety-related system cr :cnmp:nen:s has not been completed.
Ey Tetter dated April 28, 1978, the licensee contended that fire pro ection piping inside safety-related areas in H. B. Robinson, Unit 2 facflity meets Class I seismic criteria; thus Paragraph B.3.d of Branch Tecnical Position APCS8 3-1 is not applicable.
Consequently, the 1ic-:Xses provided no analysis for the subject issue.
General Design Criterion 3 in Appendix A to 10 CFR 50 requires, among cther tkings, that firefighting systems be designed to assure that their ruplte or inadvertent operation does not impair the capability of saf=2--elated structures, systems, and components.
We will require the ilcanse o provide the results of analyses to demonstrate tha: fire ec:e:=-o-systems in H. E. Robinson facility meet suc requirement.
3.2.8
.- r-e Relacement z- -eeion 3.2.8 indicates that the staff evaluat'or of the -iDe of fire r.sz needed for replacement and new installation has not been.ompleted.
- hs :1ant site visit, some linen hoses were observed tc have mildew
- n.
s mildew would cause degeneration of linen hoses rendering them s
e laz0e. hoses made of other materials less susceptive to such a a-e ac esirable.
We will require the licensee to replace the existing ey e due or replacement, by micew-Droc heat
. Dolvester sincie jacket. synthetic rL:er lin: noses t-an-30-- P y
M/.UL labe.
-c'd Weee Jtction 2.9 indicates that the staff has not cor;leted s evaluation c
raoslicense-programs intended to assre prope-functioning cated April 28, 1978, the licensee indicated that hydrants would
- once a year, in the fall.
The licensee has declined to make ec ion of hydrants on the basis that none have been damaged 86 years a-the plan:.
Nevertheless, the staf considers soection snould be a part of a prucent hydran: maintenance a- ~
coth N 2-197E and FM Data Sheets.
No. 3-2. December 1977
- e plant s-e is w t"in tne recion of f-eezing weather.
re the licensee to perform semiannual inspections of outsice