IR 05000237/1981009
| ML17252A693 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 06/03/1981 |
| From: | Grobe J, Williams C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17252A691 | List: |
| References | |
| 50-237-81-09, 50-237-81-9, 50-249-81-06, 50-249-81-6, NUDOCS 8106160495 | |
| Download: ML17252A693 (19) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
Report No. 50-237/81-09; 50-249/81-06 Docket No. 50-237; 50-249 Licensee:
Commonwealth Edison Company P. 0. Box 767 Chicago, IL 60690 License No. DPR-19; DPR-25 Facility Name:
Dresden Nuclear Power Station, Units 2 and 3 Inspection At:
Morris, Illinois Inspection Conducted:
April 2, 3, 6, 7, 9 and 10, 1981
~
{4: ~,,;,U: ~'ts Inspector: J. A. Grobe ec ~.df.*~
Approved-By:
C. C. Williams, Chief Plant Systems Section Inspection Summary:
Inspection on April 2, 3, 6, 7, 9, 10, 1981 (Report No. 50-237/81-09; 50-249/81-06)
Areas Inspected:
Routine, unannounced inspection to review the implementation of the licensee's housekeeping program and fire protection/prevention program including review of fire fighting equipment and systems, fire protection and prevention administrative controls and general employee, contractor and fire brigade trainin The inspection involved 43 inspector-hours onsite by one NRC inspecto Results:
Of the four areas inspected, no apparent items of noncompliance were identified in one area; four apparent items of noncompliance were identi-fied in three areas (timeliness of corrective action - paragraph 2; fire detection system limiting condition for operation - paragraph 2; procedures adherence - paragraphs 3 and 4; traceability of records - paragraph 3).
- DETAILS Persons Contacted
- D. Scott, Plant Superintendent
- R. Ragan, Operations Assistant Superintendent
- D. Farrar,,Administrative and Support Services Assistant Superintendent
- J. Enigenburg, Maintenance Assistant Superintendent
- E. Wilmere, Quality Assurance Coordinator
- R. Stobert, Quality Assurance Engineer B. Zank, Training Supervisor S. Mattson, Training Instructor M. Wright, Unit 3 Operating Engineer J. Wujciga, Unit 2 Operating Engineer
- E. Budzichowski, Unit Support Operating Engineer
- M. Dillon, Fire Marshall D. Reierson, Fuel Handling Foreman/Stationmen Foreman
- J. Brunner, Technical Staff Supervisor S. Powers, Technical Staff Engineer L. Sibby, Master Electrician S. Domantas, Electrical Maintenance Schedule/Analyst R. Colarelli, Electrical Maintenance Engineering Assistant D. Wandless, Lead General Mechanical Maintenance Foreman K. Neese, Mechanical Maintenance Engineering Assistant
- Indicates those persons present at the exit interview on April 10, 198.
Automatic Fire Detection, Suppression and Emergency Systems The inspector examined the licensee's automatic fire detection, suppres-sion and emergency systems including the fire water system, cardox system, halon system, detection system, penetration fire barriers, fire doors, fire dampers, and emergency lightin These systems were reviewed using the commitments and requirements in the Fire Protection Safety Evaluation Report (FPSER) dated March 22, 1978, with supporting licensee transmittals, the fire hazards analysis and the plant technical specification Areas of Inspection (1)
Procedures Number Title Dates
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DFPP 4123-4 Fire Main Valve Annual Opera-5/79, 1/80 bility DFPP 4123-5 Diesel Fire Pump Weekly Opera-11/79 through 12/79 bility (weekly)
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DFPP 4123-6 DFPP 4124-1 DFPP 4124-3 DFPP 4124-4 DFPP 4125-1 DFPP 4145-1 DFPP 4153-1 DFPP 4153-2 DFPP 4165-1 DFPP 4175-2 DFPP 4185-1 DFPP 4185-2 Diesel Fire Pump Annual Capacity Check Unit I Fire Pump Weekly Inspec-tion Unit I Diesel Fire Pump 18 Month Inspection Unit 2/3 Diesel Fire Pump 18 Month Inspection Fire System Annual Flush Cardox System Semi-Annual and Annual Maintenance Survey Requirement Unit 1 Emergency Lighting Monthly Inspection Emergency Lighting Monthly Inspection Cable Trays, Penetrations and Panels Quarterly Maintenance Fire Stop Surveillance Unit 1 Cableway Smoke Detector Control Panel Maintenance Semi-Annual Tests of Control and Computer Rooms Smoke Detectors (2)
Plant Tours 2/80, 3/81 10/79 through 12/79 (weekly)
8/79 4/79, 11/80 8/79' 8/80 4/79' 3/81 1/81, 2/81, 3/81 1/81, 2/81, 3/81 6/79' 8/79' 10/79 10/79 5/79 8/79 The inspector examined automatic fire detection, suppression and emergency systems during tours of the following plant areas: Findings Unit 1 Turbine Building Unit 2/Unit 3 Turbine Building Unit 2 Reactor Building Unit 3 Reactor Building Plant Yard (1) Violations Noncompliance (50-237/81-09-01; 50-249/81-06-01)
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10 CFR 50 Appendix B, Criteria XVI states in part, "Measures shall be established to assure that conditions adverse to quality, such as... defective material and equipment.*. are promptly
... corrected."
Commonwealth Edison Company Quality Assurance Program Topical Report CE-1-A, Revision 15, Section 16.0, states in part, "A corrective action system will be used to assure that such items as... defective material and equipment... which are adverse to quality and might affect the safe operation of a nuclear gener-ating station are promply... corrected."
Contrary to the above, fire barrier penetration seals which separate fire areas containing safety related equipment and/or cabling were identified by the licensee as defective in October, 1979, and had not been repaired when examined by the inspector on April 7, 198 *
The inspector examined seven penetration fire barrier seals which the licensee identified as being defective while perform-ing* surveillance procedure DFPP 4175-2, "Fire Stop Surveillance,"
in October, 197 Of those seven seals, four were still defec-tive on April 7, 1981:
Riser No. R306 - Unit III Trackway - Open Penetration; Riser No. R307 - Unit III Trackway - Open Penetration; Riser in Panel No. 903-55 - Unit II/III Control Room - No Flamastic Coating; Riser in Panel No. 903-56 - Unit II/III Control Room ~ No Flamastic Coatin The length of time that these seals have been inoperable is excessive and represents neither prompt nor timely correction of identified deficiencie Noncompliance (50-237/81-09-02; 50-249/81-06-02)
Dresden Units II and III Technical Specifications, Section 3.12.A, states,
" As a m1nimwn, the fire detection instrumentation for each fire detection zone shown in Table 3.12-1 shall be operable at all times when equipment in that fire detec-tion zone is required to be operabl.
With the number of operable fire detection instruments less than required by Table 3.12-1;
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L Perform an inspection of the affected zone, if accessible, within one hou Perform additional inspections at least once per hour except in inaccessible area Restore the inoperable instrument(s) to operable status within 14 days, or prepare and submit a report
- to the Commission pursuant to Specification 6.6. within the next 30 days outlining the cause of the malfunction and the plans for restoring the instru-ment (s) to operable status."
Table 3.12-1, "Fire Detection Instruments, 11 states. that the minimum number of smoke detection instruments required to be operable in the Unit 2/3 Control and Computer Rooms HVAC system is thre Contrary to the above, all of the Unit 2/3 Control and Computer Rooms HVAC System smoke detection instruments were out of service for approximately one yea Quality Assurance audit QA-12-80-39, Finding No. 1, identified on August 29, 1980 that the smoke detectors in the computer and control room HVAC system had been removed from service in July, 1979, to perform modification M12-2/3*78-The smoke detectors were returned to service on September 2, 1980, after completion of the modificatio The response to this finding did not identify the root causes that allowed this system to be removed from service and this condition to go undetected for approximately one yea Consequently, the corrective action taken was not adequate to prevent recurrence of this type of violatio Through discussions with licensee personnel, the inspector learned that the out of service probably occurred later than July, 1979, but not later than September, 197 There is no supporting documentation available to substantiate thi Licensee management (Station Fire Marshall) was aware of the out of service situation when it was initiated and subsequently when the six month surveillance requirement appeared on the weekly surveillance log sheet, but no action was taken to satisfy the technical specification action statement until after the quality assurance audit finding was written in August, 198 The Station Fire Marshall was apparently not aware of the significance of technical specification require-ments. After the quality assurance audit finding, the system was returned to service and LER No. 80-35/031-0 was submitted to the Region III office. This LER is reviewed in paragraph 6 of this repor **
(2)
Licensee Identified Items r
The following were identified by the licensee within twelve months prior to this inspectio (a)
During quality assurance audit I-81(12), the licensee identified one finding involving a surveillance procedure for an automatic fire protection system:
Finding No. 5 identified that documentation was not available to verify completion of DFPP 4165-1,
"Cable Trays, Penetrations and Panels Quarterly Maintenance," in the third quarter of 198 (b)
During quality assurance audit I-81(12), the licensee identified one finding involving a deficiency in automatic fire protection equipment:
Finding No. 6 identified a fire barrier penetration into the Unit 2 Diesel Generator room that was not properly sealed. Subsequent discussions revealed that the licensee had not developed a policy for piping penetrations in fire barrier (c)
A deviation report, No. D-12-2-81-28, identified that surveillance procedure DFPP 4145-1, "Cardox System Semi-Annual Maintenance Survey," had not been performed in the second half of 198 (d) During quality assurance audit QA-12-80-39, the licensee identified three findings concerning the automatic fire protection systems: Finding No. 1 identified that the semiannual sur-veillance procedure DFPP 4185-2, "Tests of Control and Computer Rooms Smoke Detectors," had been missed *
in the second half of 1979 and the first half of 198 Further discussion revealed that this system had been out of service for approximately one yea.
Finding No. 2 identified that monthly sampling of the diesel fire pumps fuel oil had not been occurring as required by technical specification.
Finding No. 3 identified that the monthly verification of the fire water system valve positions for Unit I had not been performed in July and August, 198,
1-(e)
Finding No. 5 in quality assurance audit I-80(12) identified that no evidence existed demonstrating that surveillance procedure DFPP 4125-1, "Fire System Annual Flush," had been performed in 197 The items listed in paragraphs (a) and (b) were identified two weeks before this inspectio All other items listed in paragraphs (c), (d) and (e) have been individually resolved by the licensee in an acceptable manne.
Manual Fire Fighting Equipment The inspector examined the licensee's manual fire fighting equipment including selected hose and standpipe stations, portable fire extinguis-hers, self-contained breathing apparatus, and other equipment available for fire fightin The equipment availability was reviewed using com-mitments contained in the FPSER with supporting licensee transmittals, the fire hazards analysis and the plant technical specification Areas of Inspection (1) Procedures Number DFPP 4114-1 DFPP 4114-2 DFPP 4114-3 DFPP 4114-4 DFPP 4114*5 Title Unit 1 Fire Equipment Monthly Inspection Reactor Building, Radwaste, Cribhouse, and Yard Loop Monthly Inspection Turbine Building Monthly.
Inspection Master List of Portable Fire Extinguishers Annual Extin-guisher Inspection Numbers Fire Hose Annual Inspection (2)
Plant Tours Dates 1/81, 2/81, 3/81 1/81, 2/81, 3/81
/
11/79, 12/79, 1/81, 2/81, 3/81 1979, 1980 1979, 1980 The inspector examined the licensee's manual fire fighting equipment during tours of the following areas:
Unit 1 Turbine Building Unit 2/Unit 3 Turbine Building Unit 2 Reactor Building Unit 3 Reactor Building Plant Yard
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'* Findings (1) Violations Noncompliance (50-237/81-09-03; 50-249/81-06-03)
Dresden Units 2 and 3 Technical Specifications, Section 6.2.A.11 states in part, "Detailed written procedures... shall be pre-pared, approved, and adhered to..* Fire Protection Program implementation."
Contrary to the above, three fire protection surveillance pro-cedures, concerning manual fire fighting equipment, were not being adhered to:
(a)
Surveillance procedures DFPP 4114-2, "Reactor Building, Radwaste, Cribhouse and Yard Loop Monthly Inspection,"
and DFPP 4114-3, "Turbine Building Monthly Inspection,"
requires actions as stated below:
- 'After inspection, initial the appropriate month [on the dated tag card on each extinguisher] stating extinguisher has been inspected."
The inspector observed four fire extinguishers in the Cable Tunnel on April 7, 1981 that did not have 1981 inspection tags and the 1980 inspection tags.had not been initialed since August, 198 These were extinguisher numbers 377, 378, 379 and 38 The inspector examined approximately ten percent of the Iire extinguishers at the plant and approximately half of them did not have 1981 monthly inspection tag (b) Surveillance Procedure DFPP 4114-4, "Master List of Port-able Fire Extinguisher Annual Inspection Extinguisher Numbers," requires that portable carbon dioxide fire extinguisher be hydrostatically tested every five year The following carbon dioxide extinguishers were examined by the inspector on April 1, 1981 and were found to be overdue for hydrostatic testing:
Extinguisher Number Location Last Test Date 253 254 Auxiliary Electrical Equipment Room Auxiliary Electrical Equipment Room
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9-75
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255A 255B 215A 332 305 Computer Room 9-75 Computer Room 9-75 U2/3 Diesel Generator Room 10-75 U3 Battery Switchgear Room 10-75 U3 Reactor Building 570' Level 10-75 Noncompliance (50-237/81-09-04; 50-249/81-06-04)
10 CFR 50, Appendix B, Criteria VIII states in part,
"Measures shall be established for the identification and control of materials, parts and components... These measures shall assure that identification of the item is maintained
... either on the item or on records traceable to the item, as required throughout... use of the ite These identi-fication and control measures shall be designed to prevent the use of... defective... parts and components."
Commonwealth Edison Company Quality Assurance Program Topical Report CE-1-A, Revision 15, Section 8.0, states in part, "A system of controls will be utilized to prevent the use of... items which have not received the required inspections and tests. Materials, parts, and components will have their identity marked on the item or on tags and records traceable to the item."
Contrary to the above, there is no traceability of hydro-static test records to fire hoses used in safety related areas either by hose serial number or by test data recorded on the hose This could result in use of defective equip-men Surveillance procedure DFPP 4114-5, "Fire Hose Annual Inspection," requires that every hose in use in the plant be hydrostatically tested yearly and the test date and pressure be indelibly marked on the hos Technical Specifications, Section 4.12.E. 4., requires that each hose at hose stations servicing areas containing safety related equipment and/or cabling be hydrostatically tested at least every three year The inspector examined hoses at the following hose stations in the Unit 3 Reactor Building on April 3, 1981 (the unit was opera~ing at 100% power):
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Station Number Fll3 F114 F117 F118 Location 545' Level, South West Wall at Bus 34-1 545' Level, North West Wall at Elevator, Near Reactor Protec-tion Instrumentation Rack 517' Level, South West Wall at Stairway, Near HPCI Motor Control Center
'517' Level, West Control Rod Drive Accumulator Area Last Marked Test Date 9-77 9-77 9-77 9-77 These hose stations are listed in Table 3.12-4 in the Technical Specifications as equipment servicing areas containing safety related equipment and/or cablin The inspector examined the procedure checksheets for the annual hose station inspection and testing performed in 197 The checksheets indicated that the hoses at these stations were hydrostatically tested in September, 1979, but this information was not recorded on the hoses and is not traceable to the fire hoses at the station The 1980 checksheets for the annual hose station inspection and testing could not be locate Further discussions with licensee personnel indicated that recording the test results on the individual hoses had inadvertently been missed, but there was confidence that every hose had been teste (2)
Licensee Identified Items The following were identified by the licensee within two weeks prior to this inspection during quality assurance audit I-81(12):
(a) Finding No. 3 identified that no documentation was avail-able to indicate satisfactory completion of DFPP 4114-5,
"Fire Hose Annual Inspection," in 198 (b) Finding No. 4 identified that DFPP 4114-4, "Portable Fire Extinguisher Annual Inspection," had not been completed in the required ti.me period in 198 At the ti.me of this inspection, these items had not been resolved by the license ** Discussion Unresolved Item (50-237/81-09-05; 50-249/81-06-05)
The inspector expressed concern over the emergency preparedness of the plant yard hose house The equipment located in the hose houses was not organized to minimize emergency response time and was not in accordance with National Fire Protection Association (NFPA) Standard No. 24-1977, Section 5-6.1, which states:
"S-6.1 When hose houses are used, in addition to the hose, each shall be equipped with:
2-Approved adjustable spray-solid stream nozzles equipped with shutoffs for each size of hose provide Fire axe with bracket I-Hydrant wrench (in addition to wrench on hydrant).
4-Coupling spanners for each size hose provide Hose coupling gaskets for each size hos.1.1 Where two sizes of hose and nozzles are provided, reducer or gated wyes shall be included in the hose house equipment."
The inspector examined the plant yard hose houses on April 3, 1981 and found the following deviations from NFPA 24-1977 and examples of poor hose house organization:
(1)
Hose laid out on hose racks, but not connected to hydrants, (2)
Hose coiled and tied as originally purchased arid not readily available for use, (3)
Hose containing standing water, (there was no evidence of hydrant leakage or use since winter, 1980 indicating that this could have been ice blockage in the hose),
(4)
Missing hose washers/gaskets, (5)
Missing gated wyes or reducers, (6)
Missing spanner wrenches, and (7)
Missing hydrant wrenche **
The licensee committed to establishing a standard layout for each hose station and upgrading the emergency response readiness of the plant yard fire hose houses by September 30, 198 This item will be examined during a future inspectio.
Fire Protection and Prevention Administrative.Controls The inspector examined the licensee's fire protection and prevention administrative controls including control of combustible materials and ignition sources, housekeeping controls, fire emergency response proce-dures, and fire protection audits and inspection These controls were reviewed using the commitments and requirements in the FPSER with supporting licensee transmittals, the fire hazards analysis and the plant technical specification Areas of Inspection (1) Procedures Number DAP 3-11 DAP 7-13 DAP 11-13 DMP 4100-1 Title Plant Cleanliness Inspection Program Control of In-Plant Permanent Storage Control of Work Over the Reactor Pressure Vessel with the Reactor Head Removed Fire Prevention Procedure for Use of Heat Sources EPIP 200-4 Fire Fighting EPIP 100-C9 Emergency Reports Checklist (2) Fire Inspection Reports Marsh and Mclennon Fire Protection Consultant Inspection Reports NML Insurance Inspection Reports (3) Plant Tours Dates i2/80 through 4/81 1/81 through 3/81 9/79' 12/80 1/80, 7/80 The inspector evaluated the effectiveness of the licensee's administrative controls during tours of the following plarit areas:
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- Findings Unit 1 Turbine Building Unit 2/Unit 3 Turbine Building Unit 2 Reactor Building Unit 3 Reactor Building Violation Noncompliance (50-237/81-09-03; 50-249/81-06-03).
Dresden Units 2 and 3 Technical Specifications, Section 6.2.A.11.,
states in part, "Detailed written procedures... shall be prepared, approved, and adhered to... Fire Protection Program implementation."
Contrary to the above, DAP 3-11, "Plant Cleanliness Inspection Pro-gram," is not being fully implemente Administrative procedure DAP 3-11 requires weekly tours of each unit to assess housekeeping controls by the responsible operating enginee The Unit 2 and 3 operating engineers have delegated this responsibility to the stationmen forema The station.men foreman, who is also a fuel handling foreman, indicated that he is not able to perform weekly inspections of the units when one unit is in a refueling outage (Unit 2 was in a refueling outage during this inspection).
He indicated that he averages an inspection every ten to fourteen day There is no documentary evidence to support this situatio During outage situations other station management personnel should be utilized to assist the stationmen foreman in this assignmen DAP 3-11 also requires that discrepancies found during the inspections, and followup actions taken, be documented on the associated checkshee These checksheets were reviewed and approximately fifty percent of the findings were missing the followup documentatio During plant tours on April 9, 1981, the inspector identified numerous improperly stored compressed gas cylinder These cylinders were filled with inert, oxidizing or flammable gase The licensee inter-prets the statement in DAP 3-11 concerning "proper" storage of com-pressed gas cylinders as meaning:
(1)
storage in designated areas utilizing holdup straps to prevent tipping; or (2)
when utilized in the plant, bottles must be restrained to prevent tipping and returned to designated storage areas when no longer in us *-
These improperly stored cylinders were located on the 517' level, Unit 3 Reactor Building near one of the Unit 3 Control Rod Drive Accumulator Area The licensee corrected these discrepancies as they were identifie Noncompliance (50-237/81-06-01; 50-249/81-04-01).
This finding was identified in IE Inspection Report 50-237/81-06; 50-249/81-0 These observations are provided for documentary purposes onl Actions to correct this item will be addressed by the licensee in response to report 50-237/81-06; 50-249/81-0 No further action on this item is required in response to this repor CFR 50 Appendix B, Criteria II, concerning the quality assurance program, states:
"Activities affecting quality shall be accomplished under suitably controlled condition Controlled conditions include
... suitable environmental conditions for accomplishing the activity, such as adequate cleanness.
"
To satisfy these requirements, Commonwealth Edison Company sub-mitted Topical Report CE-1-A, "Quality Assurance Program," which states in Section 2.2:
"Commonwealth.Edison commits to comply with... the Regula-
'
tory Position of... Regulatory Guide :.* 1.39, Rev. 2."
Regulatory Guide 1.39, Rev. 2, "Housekeeping Requirements for Water Cooled Nuclear Power Plants," Section C. states:
"The requirements for the control of work activities, condi-tions and environments at water-cooled nuclear power plant sites that are included in ANSI Standard N45.2.3-1973, "House*
keeping During the Construction Phase of Nuclear Power Plants,"
provide a method acceptable to the NRC staff for complying with the pertinent quality assurance requirements of Appendix B to 10 CFR Part 50, subject to... housekeeping activities occurring during the operations phase that are comparable to those occurring during the construction phase."
ANSI 45.2.3-1973, Section 2.1, states in part:
"The work and the quality assurance requirements for the housekeeping activities at the nuclear power plant shall be delineate The planned activities shall include the methods and techniques *.. to preserve the requisite quality of the items being constructed or installed.**
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...
,>
r-
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Cleanness requirements for housekeeping activities shall be established on the basis of... zone designations."
ANSI 45.2.3-1973, Section 2.2 states in part:
"The procedures and instructions for housekeeping practices shall be prepared.** "
ANSI 45.2.3-1973, Section 3.2 states in part:
"Control of work and storage areas where important items are handled shall be established and maintained to conform to the appropriate zone defined in paragraph 2.1 of this standar The control of all tools, equipment, materials and supplies that are used in Zones I, II, and III shall be maintained to prevent the inadvertent* inclusion of deleterious materials or objects in critical system Appropriate control measures shall be provided through utilization of such items as log books and tethered tools. 11 Contrary to the above, the licensee has not established cleanness requirements on the basis of zone designations as documented in IE inspection report 50-237/81-06 and 50-249/81-0 Also, the inspector reviewed DAP 11-13, "Control of Work Over the Reactor Pressure Vessel with the Reactor Head Removed," and found that this procedure does not fully implement the requirements of ANSI N45.2.3-197 The area over the open pressure vessel would, at least, require the restrictions designated for Zone III in ANSI N45.2.3-1973 which includes material accountabilit Section 3.2 of the standard specifies appropriate control measures for material accountability as being utilization of "log books and tethered tools." DAP 3-11 only includes a requirement to tether tools over the open vesse This does not provide the defense-in-depth approach afforded by the provisions in the standar.
Fire Protection and Prevention Training The inspector examined the licensee's fire protection and prevention training program for general employees, contractors and fire brigade member The program was reviewed using the c0111Ditments and require-ments contained in the FPSER with supporting licensee transmittals, the fire hazards analysis and the plant technical specification Areas of Inspection (1) Equipment Attendant Lesson Plans:
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(2)
(3)
(4)
(5)
(6)
- Plant Ventilation System
- Fire Water System
- Fire Detection Systems
- Cardox System
- Auxiliary Electric Equipment Room Fire Protection System Fire Brigade Initial Training Records for isi of Brigade Member Fire B.rigade Drill Records for 1979 and 1980 Fire Brigade Quarterly Training Records for 1979 and 1980 Fire Brigade Annual Practice Session Records for 1979 and 1980 General Employee and Contractor Lesson Plans Findings No apparent items of noncompliance were identified in these area Discussion 1979 1980 Unresolved Item (50-237/81-09-06; 50-249/81-06-06)
The inspector compiled the fire drill records for 1979 and 198 The results of this compilation are shown in the following table:
Percent* of Fire Brigade Numbers in Attendance at Zero Drills 47%(36)
52%(40)
One Drill 37%(28)
34%(26)
Two Drills 8%(6)
10%(8)
Three More Drills 8%(6)
4%(3)
- Num~ers shown in parenthesis are the number of fire brigade members in each categor Although the licensee has not violated his procedures or coDBDitments as approved by the NRC staff in the FPSER, he has not satisfied the intent of the training requirements in 10 CFR 50 Appendix R, Section III.1.3.b., which states:
"Drills shall be performed at regular intervals not to exceed three months for each_shift fire brigad Each fire brigade member should participate in each drill, but must participate in two drills per year."
Licensee records indicate that approximately 85 percent of the fire brigade members have not met this criteria in 1979 and 198 A similar situation exists at Quad-Cities Nuclear Power Station (QCNPS).
That unresolved item, as documented in IE inspection report 50-254/81-04; 50-265/81-04, has been forwarded to NRC headquarters for IE/NRR staff evaluatio Upon resolution of *this issue at QCNPS, action will be taken on this item at Dresden Nuclear Power Station (DNPS).
Unresolved Item (50-237/81-09-07; 50-249/81-06-07)
The fire brigade, training program at DNPS does not include utiliza-tion of fire fighting preplans or strategies to provide area specific fire fighting instruction and reference during an emer-genc This training program is in accordance with the approved program presented in the FPSER, but does not satisfy the intent of the requirements of 10 CFR 50 Appendix R, Sections III.K.11 and 1 A similar situation exists at QCNPS which is documented in IE inspection report 50-254/81-04; 50-265/81-0 That unresolved item has been forward.ed to NRC headquarters for IE/NRR staff evaluatio Upon resolution of this issue at QCNPS, action will be taken on this item.at DNP Unresolved Item (50-237/81-09-08; 50-249/81-06-08)
The inspector reviewed the training records for the fire brigade hands-on fire fighting practice sessions. Full fire brigade attendance was noted in 1979, but no session was held in 198 This is not in accordance with licensee commitaients in the area of additional fire brigade training as presented in the letter from the licensee dated July 27, 1978, Attachment 1, pages 2 and 3, and Attachment 2, pages 5 and Also 10 CFR 50 Appendix R, Section III. I.2. states that "practice sessions shall be provided at least once per year for each brigade member. n This re_quirement was not in effect in 198 This item will be examined during a future inspectio.
Licensee Event Report (LER) Review The inspector reviewed LER No. 80-35/031-0, concerning the Control Room and.Computer Room HVAC system smoke detectors, for completeness and correctness of the reported information and adequacy of the corrective actio Event Description and Probable Consequences The licensee adequately described the probable consequences, but did not completely describe the even The licensee correctly stated that the smoke detection system had been out of service for "longer than fourteen days," but did not indicate that the actual outage time was approximately one yea During that time period, from approximately September, 1979 until September 2, 1980, the out of service condition had been identified to licensee management on three occasions:
(1)
The original out of service condition was identified to licensee management, (2) The semi-annual surveillance procedure, DPFF 4185-2, for this system was identified to be performed twice on the weekly surveillance lo On all three occasions, the licensee failed to identify that the f ite protection system being out of service in a safety-related area which contained equipment that is required to be operable involved technical specification limit The LER stated that this was the "first event of this type at Dresden." This statement is correct to the extent that this apparently is the first event concerning this system at Dresde The statement is incomplete considering that two events were identified in the same quality assurance audit report where surveillance procedures were missed that are technical specifica-tion requirements to demonstrate system operability:
(1) Diesel fire pump fuel oil monthly sampling was not being performed according to technical specifications, (2) Fire water system main valve positions were not being verified on a monthly basis as specified in technical specification Cause Description and Corrective Actions The licensee described the cause of the event as being a technical specification requirement that was overlooked, but did not describe corrective actions to prevent recurrenc The LER provided only short term corrective action (functionally testing the system prior to returning it to service). The licenses's corrective actions to prevent recurrence of this type of noncompliance will be reviewed in conjuction with his response to noncompliance item 50-237/81-09-02; 50-249/81-06-02 identified in this repor At that time, the licensee will submit a revised LER which includes a complete description of the event and the root causes of the event and the appropriate corrective actions which have been taken to prevent recurrence of this type of even *
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Exit Interview The inspector met with the licensee representatives (denoted in Para-graph 1) at the conclusion of the inspection on April 10, 198 The purpose and scope of the inspection was summarized and the findings'
were discussed.
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