IR 05000254/1989023

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Insp Repts 50-254/89-23 & 50-265/89-23 on 891016-20 & 1115. Violations Noted.Major Areas Inspected:Implementation of Licensee Fire Protection Program,Including Followup of Licensee Actions on Previous Insp Findings
ML19332D538
Person / Time
Site: Quad Cities  Constellation icon.png
Issue date: 11/22/1989
From: Gardner R, Ulie J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML19332D534 List:
References
50-254-89-23, 50-265-89-23, IEIN-88-005, IEIN-88-064, IEIN-88-5, IEIN-88-64, IEIN-89-004, IEIN-89-047, IEIN-89-052, IEIN-89-4, IEIN-89-47, IEIN-89-52, NUDOCS 8912040104
Download: ML19332D538 (15)


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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

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Reports No. 50-254/89023(DRS); 50-265/89023(DRS)

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Docket Nos. 50-254; 50-265 Licenses No. DPR-29; DPR-30.

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Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name:

Quad Cities Nuclear Power Station - Units 1 and 2

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Inspection At:

Cordova, IL 61241 F

Inspection Conducted: Octooer 16-20 and November 15, 1989

' 4 v1. LANE Inspector:..,oseph M. Ulie

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A Approved By: Ronald N. Gardner, Chief tl-2 2-8 i Plant Systems Section Date

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Inspection Summary Inspection on October 16-20 and November 15, 1989 (Reports No. 50-254/89023(DRS);

No. 50-265/D9023(DRS))

Areas Inspected:

Routine, unannounced inspection to review the implementation cf the licensee's fire protection program including a follow-up of licensee actions on previous inspection findings; review of the fire protection organization; fire protection administrative controls; fire protection system surveillance' test program; verification of fire protection features; review of selected Information Notices; and work request package review. The inspector utilized inspection modules 30703, 64704, 92701, and 92702.

Results: Of the areas inspected, one violation was identified (nine examples of failing to adhere to fire protection combustible and housekeeping

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administrative procedures - Paragraph 4). Additionally, two other viole.tions were also identified; however, in accordance with 10 CFR Part 2 Appendix C, Section V.A, a Notice of Violation was not issued. The first of these violations regarded an obstructed fire sprinkler head spray pattern due to f,

wooden scaffold planking being left in-place for an extended period of time

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(Paragraph 6.d), while the second violation regarded a fire door (barrier) that l

was degraded without the licensee establishing the required continuous fire I

watch (Paragraph 6.d).

One Open Item was also identified in the report.

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l Open Item regards the length of time fire detectors are being allowed to remain inoperable (Paragraph 5).

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- Strengths observed in the licensee's program consisted of:

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The fire protection training facility located onsite allows training.

utilizing actual fire fighting activities.

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The fire fighting experience of the fire protection organization's training

department instructor and the Station Fire Marshal provide a source of

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valuable information for plant personnel during training sessions.

The sprinkler system protecting the dry resin storage area provides an

l excellent level of fire protection.

The methodology of identifying the designated Appendix R fire barriers

with a red stripe along the fire barrier well provides a readily identifiable method of distinguishing fire barrier walls.

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_o DETAILS 1.-

Persons Contacted guadCitiesStation-Ji.; Barber, Regulatory Assurance

  • D Bucknell, Assistant Technical Supervisor-
  • T. Pettit, Station Fire Marshal
  • G. Spedi, Production Superintendent Commonwealth Edison - Corporate
  • D. J. Roberts, Fire Protection Engineer

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Profescional-Loss Control, Inc.

  • D. Harrington, Staff Engineer
  • E. H.. Smith, Staff Technician U.S; NRC
  • R. L. Higgins, Senior _ Resident Inspector
  • Denotes those persons in attendance at the exit interview on October 20, 1989.

'The inspector also contacted other licensee personnel during this inspection.

2.

Actions On Previous Inspection Findings

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a.

(Closed) Violation (No. 254/85027-09; No. 265/85027-09',:

It was identified that the fire detectors required on the refuel floor were never installed as required by the plant license and as detailed in Table 3.1 of the Safety Evaluation dated July 27, 1979.

By letter dated August 18, 1989, the NRC granted an exemption to the

' licensee for a lack of a fire detection system on the refuel flocr.

Therefore..this item is considered closed, b.

(0 pen) Open Item (No. 254/88021-06(DRS); No. 265/88021-06(DRS)):

Based upon an inspector's review of the results of the diesel fire

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pump capacity test for the period of 1984 to 1987, the licensee was requested to establish more detailed fire pump assembly surveillance test criteria as follows: (1) to incorporate pump speed correction adjustments to the recorded flow and pressure measuremer;ts; (2) to record the engine speed and verify that the governor regulates engine speed within a range of ten percent between shutoff and maximum load condition of the pump; (3) to address parameters such as correction

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'0 for revolutions per minute (rpm's) and vibration testing; and (4)

-develop-or have available fire pump performance curve data in accordance with the National Fire Protection Association (NFPA) 20 criteria including the plotting of the field acceptance test and shop F

test curves to the present day fire pump performance curve.

During this inspection, the inspector obtained Procedure Number QMMS 4100-32, Revision 3, approved March 31, 1989, showing that additional steps have been incorporated into the procedure to address certain of.the above issues. For example, according to

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. licensee action item documentation, vibration tests are now being

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conducted on a monthly frequency in accordance with Procedure Number QAP 350-5. However, the procedure still does not contain performance curve data as described in NFPA 20. /secording to the corporate fire protection engineer, this data is intended to be incorporated into the plant procedure.

This item will remain open pending further l

review by the licensee of this issue and follow-up review by the NRC.

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(Closed) Open Item (No. 254/88021-08(DRS); No. 265/88021-08(DRS))

The inspector discussed with the licensee the benefit of installing bags on the carbon dioxide nozzles when conducting puff tests to verify.that all nozzles in the fire area are not obstructed.

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addition, the licensee was also requested to consider sampling the air:in rooms where carbon dioxide is discharged so as not to expose

i employees to hazardous levels of carbon dioxide. -The licensee acknowledged the inspector's observations and agreed to revise the carbon dioxide surveillance procedures.

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During this inspection, the licensee provided Procedure Number QIS 59-1, Revision 1, approved December 30, 1988, showing that steps have now been included to satisfactorily address the above issues.

Therefore, this item is considered closed.

3.

Fire Protection Organization The inspector interviewed two licensee personnel aerforming fire watch duties during grinding and welding activities. T1e inspector determined

after discussions with each of these individuals that both individuals were adequately trained. However, one of the incividuals did not recall the plant emergency number (although the individual knew the necessary actions to take) and appeared tentative in responding to inspector questions. Discussions were held between the Station Fire Protectiun Instructor, the Station Fire Marshal and the inspector regarding this fire watch deficiency. During these discussions, the inspector learned that station phones generally have the emergency number placed on the phones.

At the exit interview of October 20, 1989, the licensee stated that further consideration would be given to enhancing this aspect of the fire watch program.

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On-October 16 and 20, 1989, respectively, the inspector witnessed both the fire watch and-fire brigade training program sessions. The fire watch training sessions included classroom and hands-on training on live

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fires with the~ types of portable fire extinguishers installed in the plant.

i The-fire brigade training session covered, in part, the essentials of

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firefighting, hazardous materials and pre-fire planning so as to satisfy the shift crew's fire brigade quarterly training requirements. The lesson plan instructions provided by the instructor were found to be applicable t'o the station and the quality of instruction was considered a_ strength in the licensee's fire protection organizatien.

Additionally, the inspector reviewed licensee records to determine whether individual fire brigade members and individual shift crews were performing the required classroom and fire drill training.

The ins)ector verified that this training was being conducted in accordance wit 1 licensee commitments and license requirements.. The records identified individuals for calendar year 1989 who were in need of the quarterly training for the last quarter of 1989 so as to maintain the required fire brigade membership

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qualifications.

In addition, an unannounced fire drill was requested by the inspector.

However, at the request of the licensee, the drill was not conducted due to personnel safety concerns regarding contractor individuals involved in outage related confined space work activities.

The inspector confirmed that an agreement was in place with the local offsite fire department to respond to emergency situations, if needed, at the request of the licensee. The licensee provided a letter dated December 4, 1987, signed by the local offsite fire department senior officer (Fire Chief), agreeing to respond to the Station, if requested.

According to the Station Fire Marshal, a good working relationship exists between the Station and offsite fire department.

The licensee stated that this positive relationship has resulted in improving each organization's understanding of their roles during an emergency.

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One area within the fire protection organization where licensee staffing could be enhanced was in the fire protection group of the Technical l

Staff. At the time of the inspection visit, all fire protection Technical Staff were contractor personnel. Certain of these personnel were on-site for job specific activities only.

The inspector concluded,

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following discussions with licensee and contractor personnel during and

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after the inspection, that having in-house Technical Staff responsible for the fire protection systems who would hold this position over a long time period would prove beneficial to the plant organization.

4.

Fire Protection Administrative Controls The inspectors examined the licensee's fire protection administrative controls including: (1) Station Housekeeping Procedure No. QAP 1700-5, Revision 2, dated January 1989; (2) Flammable and Combustible Materials

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Control Procedure No. QAP 1700-1, Revision 5, dated September 1989; (3) No Smoking Areas Procedure No QAP 1700-3, Revision 1, dated November 1986; L

and (4) Fire Prevention For Welding and Cutting Procedure No. QMMP 1500-41, j

Revision 1, dated June 1988. These fire protection administrative control

procedures were reviewed using the commitments and. requirements in r

Amendment No. 52 and Amendment No. 49 to License No. DPR-29 and License No. DPR-30, respectively. These reviews also included the Fire Protection Safety Evaluation Report issued July 27, 1979; the current fire protection Technical Specifications; available supporting licensee transmittals; and the NRC guidance document, " Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls, and Quality Assurance."

The inspector's review of these procedures determined that the procedures were generally well written and were intended to minimize the amount of combustibles that a safety-related or safe shutdown area may be exposed

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to.

The inspector toured the plant on October 16, 17, 18 and 19, 1989, both

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during day shift hours and during off-shift hours to determine the effectiveness of the implementation of the fire protection administrative control procedures. The following observations were made during one or more of these plant tours:

a.

Unit 2, Diesel Generator Room - several stacks of excess unu nd combustible materials (rolled and rectangular absorbant materials)

were found left unattended while no work activity was evident.

b.

Unit 2, Reactor Building, 647' elevation - three yellow bags having plastic hoses inside of the bags were found left unattended (lying adjacent to an Appendix R designated fire barrier) while no work activity was evident, c.

Unit 2, Turbine Building, 639' elevation - a plastic bag of combustible rags was found (adjacent to a " combustible free zone")

left unattended while no work activity was evident.

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Unit 1/2, Auxiliary Electrical Equipment Room - a wooden table, chair and electronic equipment with plastic housing (each having inherent combustible characteristics) were found that were not approved by the Station Fire Marshal or his designee.

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. Unit 2, Turbine Building, turbine deck level - several individual

,i oxygen and acetylene compressed gas cylinders were found not in use in an unsecured condition (a loose metal chain was in place but dangling around the lower portion of the cylinders).

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Unit 2, Reactor Building, ground floor - at the south wall across from the south bank of control rod drives, an argon cylinder was found improperly chained to an instrument air line support.

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Unit 2, Turbine Building, 615'6" elevation, adjacent to the hydrogen oil seal unit - an oxygen / acetylene unit was found left unattended, not in use and not connected for use and did not have the gas cylinder valve protection caps in place.

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Unit 2, Turbine Building, 611'6" elevation - an oxygen / acetylene unit

was found placed immediately next to a 55 gallon drum of lube oil

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yc z left unattended..not in use and not connected for use.

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. Unit 1/2, Turbine Building, ground floor, outside the main steamline isolation valve room and the "D" Heater Bay area - two (per unit) pan e

L configured' cardboard boxes were placed in and on cable trays marked as ESS II type trays with a plastic hose running into red plastic

buckets to catch the oil _ leakage.

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'These deficiencies are considered examples of a violation (No.

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265/89023-01(DRS)) as~ described in the Notice of Violation. For several

of these individual deficiencies, the licensee took corrective action

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prior to the inspector departing from the site. At the exit interview on October 20, 1989, the licensee indicated that several of the above o

deficiencies appeared'to be in areas where Unit 1 outage related-(contractor) activities were being performed.

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Fire Protecticn System Surveillance Test Program The inspector reviewed, in part, the licensee's fire protection system surveillance test program required by Technical Specifications and other licensee fire protection surveillance test procedures. This review

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censisted of witnessing an in-progress penetration fire barrier

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surveillance = test, witnessing a simulated actuation of a fire door assembly hold open device, a visual verification of fire protection water and carbon dioxide systems for proper valve positioning, a selective review of the fire detection system, and a visual inspection of randomly selected fire hose stations to determine their operability. The review identified the following:

On October 16, 1989, the inspector accompanied the contractor Technical Staff personnel performing the once per operating cycle (Technical Specification _Section 4.12.F.1) surveillance test of designated safety-related penetration fire barriers (No. QTS 170-1, Revision 9, dated October 1988). The inspector determined that these l

personnel were satisfactorily performing this surveillance test to assure that the fire barrier's integrity was intact. Although minor

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discrepancies were identified in the drawings being used, sufficient detail was provided in combination with the F-drawing (specific to the Appendix R designated fire barriers) and on the Penetration Fire Stop Data Sheets for the surveillance personnel to ascertain penetration location correlations.

On October 19, 1989, at the inspector's request., the licensee's

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Instrument and Maintenance Group conducted surveillance test procedure No. QIS 67-1, Revision 4, dated December 1988, on the fire door located in the Turbine building, mezzanine level, separating Unit 1 and 2 areas.

In accordance with the surveillance procedure, the licensee simulated the actuation of a local area fire detector so as to verify that the electromagnetic device connected to the fire door assembly would deactivate and allow the fire door to close. The

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surveillance test was conducted successfully.

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  • j During plant tours on October 16, 17, 18, and 19, 1989, the

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inspector.. accompanied by licensee or contractor personnel, performed

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e a walkdown of critical fire protection water and carbon dioxide system valves. -These tours included-the'cribhouse, turbine

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building, reactor building and yard areas.

The licensee provided the inspector with the following(monthly and annual fire protection valve surveillance procedures:

1) QAP 300-24, Fire Suppression Valve Locks, Revision 2, dated July 1988; (2)-

.QOS.4100-2, Annual Suppression System Valve Operability, Revision 5, dated May 1986; and (3) QOS 4100-4, Monthly Fire Suppression Valve Position Inspection, Revision 4, dated December 1988.

Each of the valves-(e.g. outside screw and yoke valve and post indicator valve)

inspected were found locked, chained, sealed, and/or electrically

supervised in the proper position.

In addition, the carbon dioxide low pressure storage tank level and pressure were verified to be

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within Technical Specification limits.

During a walk-through with a control room operator regarding the

operation of the control room fire detection system equipment, the inspector learned that four fire detectors have been out of service from seven months to one year and seven months. These fire detector devices are identified as (1) 64-10 - out of service since March 2, 1988; 71-25 and 71-26 - out of service since January 9, 1989; and 52-05 - out of service since March 3, 1989. The concern raised by s

the inspector regards the length of time these fire detection devices have been out of service. As.a result of discussions between the inspector and Instrument and Maintenance personnel, the inspector determined that the part on order for fire detection device 64-10 arrived on-site September 19, 1989, and was to be scheduled for installation in the near future. With. regard to the other out of service fire detectors, the reason provided by the licensee for the delay in repairing these components is that a different vendor than the one who originally supplied the fire detectors is now being used.

This requires a Technical Staff review prior to the new parts being used. -This technical review was still in-progress. The licensee acknowledged the inspector's concern at the exit interview on October 20, 1989, and indicated that a more prompt corrective action plan would be strived for.

The inspector categorized the concern over the length of time fire

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detectors remain out of service as an Open Item (No. 254/89023-01(DRS);

No. 265/89023-02(DRS)). Although, the above specified fire detectors were out of service, sufficient numbers of additional fire detectors within the respective fire zones were in service and available to meet minimum NRC requirements.

During plant tours on October 16, 17, 18, and 19, 1989, the inspector

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performed a selective sampling of fire hose stations to confirm that these stations were ready for use. The inspector confirmed that the associated fire hose station control valves were closed, fire hose including appropriate nozzles were in place, including a check of the

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last hydrostatic test of the fire hose. The inspector also verified accessibility to the fire hose' stations. No deficiencies were observed during these checks.

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Verification of Fire Protection Features The inspector selectively examined. fire protection modifications. described in the NRC's Fire Protection Safety Evaluation Report for the Quad Cities Nuclear Station (issued July 27,1979) to determine whether the licensee was maintaining the required fire protection features in accordance with Amendment No. 52 for Unit 1 and Amendment No. 49 for Unit 2.

During plant tours conducted on October 16-19, 1989, the inspector observed the status of the following. fire protection features:

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Fire Detection Systems The inspector confirmed that fire detection devices were being

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l maintained in the auxiliary electrical equipment room, battery and charger equipment rooms.

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'b.

Water Suppression Systems

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The inspector confirmed that fire water suppression systems were being maintained in the cable spreading room, over the diesel driven fire pumas in the Unit 1 and 2 trackway areas, turbine building j

electro-1ydraulic control oil reservoirs and over the 2A control rod j

drive feed pump. However, during plant tours on October 16-18, 1989,

'the inspector observed that directly above the 2A-302-3 control rod

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drive feed pump, scaffolding assembly No.89-043 was obstructing the sprinkler head spray patte " of the installed sprinkler system. The wooden planking also consOtuted a combustible hazard. A review of the Scaffolding Acceptance 'ag ind'.cated the scaffolding had been in place since February 8, 1989. The Scaffolding Coordinator confirmed that the scaffolding had been erected at approximately that time.

The inspector performed a review of scaffolding procedures No. QAP 1500-7, Administration of Scaffolding, Revision 1, dated June 1988 and QMMP 1500-41, Erecting Scaffolding, Revision 1, dated June 1988.

Step E.9 of QMMP 1500-41 specifies that scaffolding will n t prevent q

fire protection equipment from performing its intended function (i.e.

sprinkler systems). Subpart a. specifies that if blocking of fire protection equipment cannot be avoided, contact the Station Fire Marshal so that compensatory measures can be established prior to erecting the scaffold. No compensatory measures had been established.

Step C.4.d of QAP 1500-7 specifies that the Scaffolding Coordinator is required to conduct periodic inspections of scaffolding to assure continued compliance with the requirements identified in QMMP 1500-41.

Both procedures address noting on the Scaffolding Acceptance Tag the estimated duration of the job but no specific criteria was provided detailing a maximum time the scaffolding can remain in place.

In discussions with the Scaffolding Coordinator and Station Fire Marshal, the inspector learned that instances in the past have occurred whereby the wooden planking was removed and the scaffolding assembly

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R was allowed to remain in place so as not to prevent the sprinkler

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L system spray 3attern from being obstructed. The inspector was i-concerned wit 1 the extended period of time, eight months, that the wooden planking was allowed to remain in place. Each of the days

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'(day and off-shift hours) that the inspector observed.the scaffolding assembly, no work activity was in progress. The inspector informed-the= licensee that this scaffolding installation, which created a:

sprinkler head spray pattern obstruction, was a violation (No.

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265/89023-03(DRS)) of the plant procedures. This violation had minor safety significance. The other fire sprinkler system heads in the area were considered sufficient to be able to prevent a fire from propagating.

In addition, the inspector verified that the wooden planking had been removed.

This violation meets the tests of 10 CFR Part 2 Appendix C, Section V.A., consequently, no Notice of.

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Violation will be issued and this matter is considered closed.

c.

Foam Suppression Equipment The inspector confirmed that foam suppression equipment including a cart with fire hose, foam educator and foam were being maintained at the fire brigade assembly area.

d.

Fire Barriers

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The inspector confirmed that the fire barriers for the cable spreading room including the-fire-doors and penetration fire seals-were being r.aintained.

L While conducting a plant tour during an off-shift on October 19, 1989, the inspector observed a designated fire door located in the Unit 2 Reactor Building, outside of the interlock area, with a hold open device whose condition could have prevented the fire door from latching. The hold-open device was operable and the door would have closed. However,.the door may not have latched due to damage to the handle mechanism (stuck). The door was known to have had a handle

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mechanism problem for approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and was tagged to reflect the handle mechanism problem. The fact that the fire door l-might not have latched in a fire condition rendered the door technically inoperable.

I In accordance with Technical Specification Section 3.12.F.2, with a penetration fire barrier not intact (e.g. potential for the fire door l

latching mechanism to be stuck in the non-latching position) the l

licensee is required to establish a continuous fire watch on at least L

one side of the affected penetration within one hour.

However, according to the shift engineer, the fire door was believed l

operable because the hold open device was operable. The shift engineer was unaware of the latching problem. After learning about

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h the sticking handle mechanism, the shift engineer took prompt action l-to have the door repaired.

The fire door handle mechanism was replaced l

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'and the fire door was placed back in-service prior to the inspector's (

departure from the site.

It was determined that the licensee's I

failure to properly establish a continuous fire watch was an isolated instance of a violation-(No. 265/89023-04(DRS)) of Technical Specifications. :The fire detection system for this' location was o)erable and combustible loading was deemed to be low. Therefore, t11s fire door deficiency had minor safety significance. This violation meets the tests of 10 CFR Part 2, Appendix C, Section_V.A.;

consequently, no Notice of Violation will be issued. This matter is considered closed.

Also, during a plant tour the inspector observed a designated Appendix R fire barrier (red painted stripe along wall) 3enetration that was not identified. This penetration component was t1e door at the Unit 1

Heater Bay area entrance of the Turbine Building. According to the

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fire protection contractor assigned to the Technical Staff and the

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Station Fire Marshal, the designated Appendix R fire barrier was

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incorrectly marked and a program to correct any other such deficiencies

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was underway. The inspector informed the licensee that this program should be completed in a timely manner to assure all required fire

. barriers are properly identified.

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Water' Damage Protection

The inspector confirmed that certain electrical cabinets, switchgear i

and/or motor control centers specified in the safety evaluation and j

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located'in the Reactor Building, mezzanine floor _ level and the Turbine

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Building, mezzanine floor' level were being protected to reduce the i

potential for water damage from hose streams. The inspector informed l

the Station Fire Marshal that the plastic sheeting protection provided j

over the.4 kv switchgear appeared to be questionable as to its

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effectiveness due to its placement and unknown ability to maintain i

its integrity.

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Emergency Lighting During a plant tour on October 17, 1989, emergency lighting unit No. 33E' located in the Reactor Buil ing, 623' elevation at column line M-8 was observed to have its warning light lit and was believed to be inoperable. The inspector contacted the shift control room engineer-to determine if this lighting unit was required for post fire safe shutdown. After a review of the post fire safe shutdown procedure and drawings, it was determined that this lighting unit was required for life safety and not post fire safe shutdown capability.

The Station Fire Marshal followed up in contacting electrical maintenance personnel (responsible department) and

. informing them of the lighting unit deficiency.

Subsequently, during the week of November 6, 1989, one of the resident inspectors during plant tours observed three additional emergency lighting units that had their unit lights illuminated or had no power being supplied. The units were located as fo!1ows:

(1) Lighting Unit No. 12 located at the south end of the Reactor

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Building, approximately 623' elevation level near the "B" clean-up n[

pump room (Unit 1); (2) Lighting Unit No. 43H2 located in the Southeast

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Corner Room on the south wall (Unit 1);.and (3) Lighting Unit No. 42

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located at the torus area near the door to the RCIC and "B" core spray room (Unit 1). A resident inssector-informed the electrical

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' maintenance Superintendent and the s11ft operating engineer of these

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lighting unit deficiencies. A review is in progress to determine the function of these three lighting units..The shift operating engineer l

stated that dedicated portable handheld lighting-units for post fire-safe shutdown capability are maintained at strategic plant locations.

The inspector learned that Work Request No. N5329 was written for one of'the three deficient lighting units on August 6, 1989. However, the licensee should consider taking more timely. corrective action to

' repair or replace these lighting units.

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7.

Review of Selected-Information Notices

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The inspector _ requested licensee evaluations of Information Notice (IEN)

No. 88-05, Fire In Annunciator Control Cabinets, responses dated May 23

and 26, 1988, and June 2, 1988; IEN No. 88-64, Reporting Fires In Nuclear

.i Process Systems At Nuclear Power Plants, response dated October ~27, 1988;

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-IEN No. 89-04, Potential Problems From the Use of Space Heaters, response

(action completed) dated July 28, 1989; IEN No. 89-47 Potential Problems with Worn'or Distorted Hose Clamps on Self-Contained Breathing Apparatus,

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responses dated June 8,,1989 and September 14, 1989; and IEN No. 89-52

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Potential Fire Damper Operational Problems, draft response dated-l September 30,x1989.

IEN No. 88-05 addresses fires initiating in annunciator panels manufactured

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by Electro Devices, Inc. According to the licensee's electrical maintenance department evaluation, the Quad Cities Station annunciator panels are not manufactured by Electro Devices, Inc. and no instances of fires in control i

cabinets have occurred. An additional licensee evaluation of this IEN

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noted that loss of annunciator procedures exist. These procedures include inspections for restoration of equipment. If a fire occurs in an annunciator

3anel the licensee has personnel trained in the use of self-contained areathing apparatus and guidelines are in place to mitigate this condition.

Based on the above, this evaluation was determined to be satisfactory to

' address the issue.

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IEN No. 88-64 addresses the importance of licensees having appropriately detailed procedures and guidelines so as to make timely notification to the NRC Operations Center of events involving fires in nuclear process systems.

In discussions held with the Station Fire Marshal on October 26, 1989, a revision to the General Site Emergency Plan for an unusual event-is planned. This revision regards specifying a time guideline of approximately ten minutes for the brigade to extinguish a fire (in important to safety plant areas) before an unusual event would be declared and other reporting actions would be initiated. Based on the above, the licensee's planned actions are in accordance with NRC criteria to address the IEN.

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IEN No. 89-04 regarded potential problems that may result from the

$mproper use of space heaters. The IEN specifically identified a 13 kw heater. ~According to the licensee's evaluation, the Station has two 13.5 kw. heaters that are used for additional heat in the mechanical maintenance

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shop during the winter. Since the IEN was issued, the licensee as a precaution has installed signs on these heaters cautioning users to consider the placement of these heaters near equipment due to the potential

. fire hazard.-The Station also allows the use of low voltage heater units

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in office areas and outside areas such as for security personnel. However, according to the Station Fire Marshal, the use of space heaters in safety-related or safe shutdown areas of the plant are controlled by Procedure QMMP 1510-21, Fire Prevention For Welding and Cutting Activities, Revision'1, dated January 1988. This procedure implements the use of a

permit system that includes a fire prevention inspection of the area prior to the work beginning. During plant tours on October 16-19, 1989, the-inspector observed that during grinding and welding activities the permit system was being 3roperly implemented. The' inspector did not observe the

use_of any space 1 eaters in safety-related or safe shutdown areas of the

plant.

Based on the above, this evaluation was determined to be satisfactory to address the issue.

IEN No. 89-47 alerted licensees of )otential problems with worn or distorted hose clamps on self-contained breatling apparatus. According to the licensee's evaluations, corrective actions taken included a procedural revision specifically checking the clamps at each end of the hose and discussion of this IEN at Radiation Protection Department safety meetings (Radiation Protection personnel perform surveillance inspection and limited maintenance on breathing apparatus equipment) and reviewing applicable breathing apparatus procedures relative to inspection and maintenance of breathing apparatus equipment.

Based on the above, this evaluation was determined to be satisfactory to address the issue.

3.

IEN No. 89-52 addresses potential problems affecting the closing reliability of curtain-type fire dampers under ventilation system operational air flow conditions. Acenrding to the licensee's evaluation, the Station's pre-fire plans currently contain the following caution where applicable:

... fire damper (s) may not close in the presence of air flow. Fixed

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ventilation system may need to be tripped to insure closure of fire dampers." The inspector selectively sampled pre-fire plans that did contain the above caution. Based on the above, this evaluation was determined to be satisfactory to address this issue.

8.

Work Request Package Review The inspector examined Work Request Forms No. Q75753, Q75754 and Q64295. The first two work requests regarded the need to inspect each sprinkler head on the wet pipe sprinkler system above the Unit 1 and 2 Turbine Oil Reservoirs for paint overspray. Appropriate guidance was given in the work requests for replacing any painted sprinkler heads with sprinkler heads of the same type, orifice and temperature rating.

According to Work Request No. Q75753, the Unit 1 Turbine Oil Reservoir sprinkler system had 38 sprinkler heads replaced while Work Request No. Q75754 for the Unit 2 Turbine Oil Reservoir sprinkler system specified 43 sprinkler heads had been replaced.

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During plant tours on October 16, 17, 18 and 19, 1;89, including the Unit 2 Turbine Oil Reservoir area, the inspector did not observe any painted sprinkler heads. However, the inspector was not able to verify other required sprinkler head characteristics such as sprinkler-head temperature rating, etc. due to the height of the sprinkler system from the floor.

The third Work Request was initiated to extend the-suction line of the

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-1/2 B diesel fire pump after a low water level condition caused insufficient

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suction head resulting in the fire pump being damaged on February 9, 1988 (Deviation. Report No. 4-1-88-014). The licensee provided details regarding the diesel fire pumps.

The previous suction screen elevation was 565'6" which provided a 3'6"

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pump submergence, assuming that the water level under the cribhouse didn't drop below the " low" of 570'.

During the event referenced above, however, this did occur due to excessive cribhouse screen blockage as the water level dropped to 566'6".

Extending the suction line will substantia 11y' reduce the likelihood of fire pump damage should this unusual " low, low" water level ever reoccur. Additionally, the licensee initiated a Station Modification Review Form to determine if providing

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level indication for the cribhouse interior bays was feasible. An acceptable 5 foot extension length was s3ecified by the pump manufacturer (Layne & Bowler, Inc) after a review of aay depth and pump critical speed boundaries.

The previous suction line consisted of three sections connected by threaded couplings, with the two-stage pump and intake screen flange mounted below

.(see' sketch 1). The new 5 foot suction pipe and shaft assembly was added between the middle and lower existing sections and was installed and coupled'in the same manner for the 1/2 B fire pump. This enhancement was reviewed by the Station Modification Review Committee (SMRC) on February 17,

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1988, and declared not to be a modification; however, manufacturer concurrence was deemed necessary and a floor loading review was requested by the SMRC members.

Subsequently, the licensee received the results of two reviews, one by the fire pump vendor and the other from Sargent and Lundy satisfying the SMRC's directive.

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The extension of the suction line for the 1/2 B diesel fire pump was installed and tested satisfactorily under Work Request Numbered Q64295.

The extension of the suction line for the 1/2 A diesel fire pump is scheduled for installation within approximately 30 days after the fabricated components arrive on site.

9.

Open Item Open Items are matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or licensee or both. An Open Item discussed during the inspection is discussed in Paragraph 5.

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Violation For Which A " Notice of Violation" Will Not Be Issued np

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The NRC uses the Notice'of Violation as a standard method for formalizing the existence of a violation of a legally binding requirement. However, 10 CFR Part 2, Appendix C, Section V.A has been changed to provide the-staff with the flexibility not to issue a Notice of Violation for inspection findings. Such violations are by definition of minor safety

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Concern.

Two violations of regulatory requirements identified during the inspection for which a Notice of Violation will not be issued are discussed in Paragraph 6..

11. Exit Interview.

The inspector met with licensee representatives (denoted in Paragraph 1)

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at the conclusion of the inspection on October 20, 1989, and summarized the scope and findings of the inspection.

The inspector also discussed the likely informational content of the inspection report with regard to documents reviewed.by the inspectors during the inspection. Also,-on

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November 15, 1989, a conference call was held between the inspector and

'the Production Superintendent to discuss the final categorization and status of the inspection findings. The licensee did not identify any of the documents as proprietary.

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