ML14192A110
| ML14192A110 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 11/24/1980 |
| From: | Eisenhut D Office of Nuclear Reactor Regulation |
| To: | Carolina Power & Light Co |
| References | |
| NUDOCS 8101140830 | |
| Download: ML14192A110 (4) | |
Text
UNITED STATES 0lT E5k NUCLEAR REGULATORY COMMISSION WASHINGTON. D. C. 20555 November 24, 198 Docket No. 50-261 Plant Name: H. B. Robinson 2 TO ALL POWER REACTOR LICENSEES WITH PLANTS LICENSED PRIOR TO JANUARY 1, 1979 The Commission published on November 19, 1980 (45 FR 76602), a revised Section 10 CFR 50.48.and a new Appendix R to 10 CFR 50 regarding fire protection features of nuclear power plants. The revised Section 50.48 and Appendix R will become effective February 17, 1981, which is 90 days after publication. A copy of the Federal Register Notice is enclosed (Enclosure 1).
The provisions of Appendix R that are applicable to the fire protection features of your facility can be divided into two categories.
The first category consists of those provisions of the Appendix that are required to be backfit in their entirety by the new rule, regardless of whether or not alternatives to the specific requirements of these Sections have been previously approved by the NRC staff. These requirements are set forth in Sections III.G, Fire Protection of Safe Shutdown Capability; III-J, Emergency Lighting; and III-0, Oil Collection Systems for Reactor Coolant Pump. The fire protection features of your facility must satisfy the specific requirements of these three Sections by the dates established by Paragraph 50.48(c), unless an exemption from the Appendix R requirements is approved by the Commission. You should note the provisions for tolling the time for completing the modifications required by these three Sections of Appendix R set forth in Paragraph 50.48(c)(6).
The second category of Appendix R provisions applicable to the fire protection features of your facility consists of requirements concerning the "open" items of previous NRC staff fire protection reviews of your facility. An open item is defined as a fire protection feature that has not been previously approved by the NRC staff as satisfying the provisions of Appendix A to Branch Technical Position BTP PCSB 9.5-1, as reflected in a staff fire protection safety evaluation report. The fire protection features of your facility that are in this category must satisfy the specific requirements of Appendix R by the dates established by Paragraph 50.48(c), unless an exemp tion from the Appendix R requirements on those features is approved by the Commission. is a summary listing of the open items concerning the fire protection features of your facility based-on a review of our records. Also included is our position on the specific requirements that must be satisfied in order to resolve these open items. If you have any questions or disagree ments with this enclosure, please advise us within 30 days.of your receipt of this letter.
810 114 0
-2 With regard to the fire protection modifications that have been previously approved by the NRC staff, Paragraph 50.48(d) specifies a new schedule for their completion. This paragraph, when it becomes effective, will supersede the currently effective section of the regu 1 at i-ons-that-tempora-rily--suspends--
copletion dates for previously approved fire protection modifications that are given.in facility license conditions (45 FR 71569, October 29, 1980).
The Commission expects that all such modifications will be completed in accordance with this new schedule, unless an extension has been requested and granted by the Director of the Office of Nuclear Reactor Regulation
[see Paragraph 50.48(d)], or an exemption has been requested and granted by the Conmission pursuant to Section 50.12 of the Commission's regulations.
If you have previously requested extensions of dates for completion of modifications that are required by license conditions for your facility which were not approved, and you have determined that these extensions are still necessary and justifiable, it will be necessary for you to reapply for any such extensions in accordance with the provisions of Paragraph 50.48(d).
All requests for Cormission action resulting from this rule-are subject to the schedule of fees soecified in 10 CFR 170.21. If you have any questions concerning the subject matters of this letter, please contact the NRC Project Manager for your facility.
Sincerely, Darrell G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation
Enclosures:
- 1.
Notice - Fire Protection Rule
- 2.
Summary of Staff Require ments to Resolve Open I tems cc w/enclosures:
See next page
SUMMARY
OF STAFF REQUIREMENTS TO RESOLVE OPEN ITEMS H. B. ROBINSON 50-261 3.1.21 Lube Oil Shielding System In the SER, it was our concern that lube oil from the reactor coolant pump could come in contact with hot surfaces and start a fire.
By letter dated June 12, 1980, the licensee proposed to install a manually actuated sprinkler system using horizontal sidewall sprinklers to protect the reactor coolant pumps, adjacent reactor coolant piping, and pump bay floor area. The water supply to this sytem would be isolated during normal power operation. The system of heat and flame detectors over each pump area will alarm in the control room and the control room operator will remotely activate the deluge valve.
A manually actuated sprinkler system does not meet our guidelines for protection of reactor coolant pumps.
Also, Section 4-5.4 of NFPA 13 1978, Standard for Installation of Sprinkler Systems, requires sidewall sprinklers to be installed close to ceilings and walls unless special construction arrangements make a different position advisable for prompt operation and effective distribution. The principal reason for this is that sprinkler operation will be delayed considerably without some means of assuring that the sprinkler is in the flow of hot gases from the fire.
Based on our review, we find that a manually actuated sprinkler system would not be adequate to prevent a fire in the event of a leak from the RCP lube oil system and, therefore, is not acceptable.
To meet Section III, Paragraph 0 of the Appendix R to 10 CFR Part 50, the licensee should provide an oil collection system for the RCP lube oil system.
3.1.24 Electrical Cable Penetrations In the SER, it was our concern that the electrical cable penetration fire stops may not be adequate to prevent a fire from spreading via the penetration.
By letter dated November 6, 1980, the licensee has proposed to submit the results of fire tests of electrical cable penetrations by December 1, 1980.
To meet Section III, Paragraph M of the Appendix R to 10 CFR Part 50, the licensee should provide cable penetration seals which utilize only non combustible materials and should be qualified by tests that are comparable to those used to rate fire barriers.
-2 3.2.1 Alternative Shutdown System To meet Section III, Paragraph G of the Appendix R to 10 CFR Part 50, an alternative shutdown capability, independent of the control room, the cable spreading room, the electrical equipment room and other critical areas is required. The licensee has submitted a proposed modification to fulfill this requirement.
We have not yet completed our review of this item. The alternative shut down capability must meet the requirements of Section III, Paragraph L of Appendix R to 10 CFR 50.