IR 05000298/1989024
| ML20247G864 | |
| Person / Time | |
|---|---|
| Site: | Cooper |
| Issue date: | 09/06/1989 |
| From: | Clay Johnson, Murphy M, Singh A, Stetka T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20247G857 | List: |
| References | |
| 50-298-89-24, NUDOCS 8909190158 | |
| Download: ML20247G864 (15) | |
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APPENDIX B
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U.S. NUCLEAR REGULATORY COMMISSION.
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REGION IV
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NRC-Inspection Report: 50-298/89-24 Operating License: DPR-46.
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Docket: 50-298 Licensee: : Nebraska Public. Power District (NPPD).
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P.O. Box ~499:
Columbus, Nebraska 68602-0499 Facility Name:.CooperNuclearStation.(CNS)
. Inspection At: CNS, Brownsv'ill'," Nebraska e
Inspection Conducted-July 31 - August 4, 1989 I
Inspectors:
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A. Singh, Refac ;or7 nspector, Plant Systems-Date0-
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Section, DYvlsion of' Reactor Safety.-(Team Leader),
C 9a,A L \\\\AO g-s&
C. E. Johnson, React Inspector, Plant Date Systems Section, D sion of' Reactor Safety Wbk WI/pr9 M. E. Murphy, Reactor Inspector Test Programs Date Section, Division of Reactor Safety Accompal:ying Personnel:
D. Arnold, Rolf Jenson and Associates H. Thomas, Science Applications International Corporation (SAIC)
Approved:
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T. F. Stetka, Chief, Plant Systems Section Date '
Division of Reactor Safety 8909190158 890912 PDR ADOCK 05000298 Q
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Inspection Summary Inspection Conducted July 31 through August 4, 1989 (Report 50-298/89-24)
Areas Inspected: Special, announced triennial postfire safe shutdown capability reverification and assessment and implementation of the fire protection program in compliance with the requirements of Appendix R to 10 CFR 50.
Results: The inspection verified that the licensee has properly maintained the postfire safe shutdown capability which was confirmed in the initial validation inspection conducted during April 21-25, 1986.
Items requiring licensee action as a result of the initial inspection were found to be completed and the initial concerns resolved. The inspection also reverified that the licensee has continued to. carry out an overall effective fire protection program.
However, there appeared to be a weakness in the area of plant design modification procedures..This weakness involved a noncited violation (paragraph 2.a) for failure to follow the procedures in the area of plant modifications and a deviation (paragraph 2.g) for not carrying out a commitment.
The licensee's configuration management program and the management involvement as it relates to maintaining Appendix R compliance represents one of the strengths of the licensee's overall fire protection efforts.
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l DETAILS i
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1.
Persons Contacted NPPD
' *G. R. Horn, Division Manager, Nuclear Operations
- G T. Smith, Quality Assurance, Manager
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- J..M. Meachum,' Senior Manager of Operations
- H. T. Hitch, Plant Services Manager-
- E. M. Mace, Engineering Services Manager.
- M. T. Boyce, Licensing, General Office
- M. A. Hillstron, Assistant Mechanical Supervisor
- E. Layne, Fire Protection Engineer, General Office
- R. Brungardt, Operations Manager
- G. Stenger. Engineering Technician
- F. Alderman, Cooper Nuclear Station (CNS), Fire Chief
- L. E. Bray, Regulatory Compliance Specialist
- G..R. Smith, Licensing Supervisor R. L. Gibson, Audit and Procurement, Quality Assurance Supervisor Other Licensee Personnel
- R. Lemos, Appendix R Project Engineer, Engineering Planning and Management (EPM)
- K. Cloran Electrical Engineer. EPM
- S. Chingo. Fire Protection Engineer, Impell Corporation
- Denotes those attending the exit interview conducted on August 4,1989.
The inspectors also interviewed other CNS personnel during the inspection.
2.
Triennial Postfire Safe Shutdown Capability Reverification (64150)
The purpose of this inspection was to determine whether the licensee had developed and implemented a configuration maragement program with respect to postfire safe shutdown capability. This inspection was also to determine whether the licensee has maintained the postfire safe shutdown capability achieved during the initial validation inspection conducted during the period April 21-25, 1986.
a.
Configurai. ion Management Program In order to verify thet the configuration management program related to Appendix R compliance and postfire safe shutdown capability was adecuate, the inspectors conducted a detailed review of plant and corporate p)rocedures governing the preparation and review of design change (DC documents. This was done to determine that these procedures:
1) include provisions that ensure all DC documents are reviewed for Appendix R compliance and postfire safe shutoown
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concerns, 2) provide adequate guidance for the reviewer to determine
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if there is impact on Appendix R compliance and the postfire safe
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shutdown capability, and 3) include provisions to ensure that all DC documents which do impact Appendix:R compliance and postfire safe shutdown capability are incorporated into the analyses, procedures,
and programs which support and implement this capability.
I In addition, to verify the implementation of these procedures, the j
inspection tearn selectively reviewed DC documents for modifications j
to those p % t systems required for postfire safe shutdown.
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(1) Configption Control Procedures The following procedures, which govern the review of design change packages (DCP), were reviewed:
CNS Engineering Procedure Title Date
3.4.3, Revision 0 Design Change 12/5/88 3 4.4, Revision 3 Temporary Design 12/5/88
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Change 3.4.6, Revision 0 Design Review 12/5/88 Checklists 3.4.10, Revision 0 Revisions, Amendments, 12/5/88 and On-the-Spot Changes DCs are initiated by a design engineer to satisfy the requirements of CNS Procedures 3.4.3, 3.4.4, or 3.4.10.
CNS Procedure 3.4.6 contains checklists for the evaluation of Appendix R and fire protection concerns. These checklists are included in this procedure as Attachment D, " Fire Protection / Appendix R Design Evaluation Review Checklist" and Attachment H, "CNS Safe Shutdown Components / Systems."
The first page of Attachment B requires that the design engineer conduct a preliminary fire protection evaluation and indicate by
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a "yes/no" answer if a proposed modification may irrpact certain fire protection features. A "yes" answer requires that the Appendix R coordinator and other designated individuals perfom I
a review of the modification. The Appendix R coordinator will l
initiate a review of the DCP by a fire protection engineer.
i The inspectors noted that fire protection engineer approval was triggered only after the design engineers 1dentified the fire protection concern. The inspectors also noted that no formalized training program was in effect to train the design engineers in identifying such concerns.
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-5-Since all DCPs receive subsequent review by the Station Operations Review Committee (50RC), an additional opportunity to evaluate the changes' impact on the plant Appendix R program is provided.
(2) Implementation of Configuration Control Procedures The inspectors reviewed the following DCPs to verify that procedures for configuration control were adequately implemented:
DC-86-021 DC-87-096, Revision 1 DC-87-037 DC-87-132 DC-87-073 DC-87-189 DC-87-096 DC-87-191 The above DCPs had been reviewed in compliance with the applicable CNS engineering procedures.
As a result of their review, the inspectors determined that the procedure was incorrectly applied for DC-87-132. The design engineer had indicated that the change had no impact on fire suppression systems on the Attachment B checklists included in the design package. However, the change did affect the fire
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suppression system for the diesel generator rooms. Based on reviewing the DCP, the design engineer was aware of this impact but determined that this impact did not affect the operability of the system. As the result of this decision, a negative checklist entry was made which therefore bypassed an evaluation of this change by a fire protection engineer.
The licensee was informed that this represented a nonconformance to Procedure 3.4.6, " Design Review Checklists," and was an apparent violation.
The licensee agreed to take the following actions to reinforce the configuration control program:
Develop formal training requalification program for design engineers regarding Appendix R configuration and in identifying effects on the fire protection program.
Review the current checklist review process to enhance fire protection engineer input.
Review the overall configuration control program to oetermine if any additional program enhancements are indicated.
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-6-As an interim measure, distribute an internal notice to design engineers at the NPPD General Office and the CNS site which highlights methods to assure that DCs are properly reviewed for their impact on the fire protection program.
The licensee has committed to complete activities by the next refueling outage.
Based upon these corrective actions and the minor safety significance of this occurrence, in accordance with the revised enforcement policy, a Notice of Violation is not being issued.
b.
Postfire Safe Shutdown Procedures (1) Procedure Review The inspectors reviewed the Operations Department's Appendix R postfire safe shutdown procedures to determine that any revision made to the procedures did not impact the licensee's postfire safe shutdown capability.
The following procedures were in place to address fire initiated.
component or system malfunctions:
Procedure Number Title Date System Operating Procedure Operations of Diesel 6/10/89
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2.2.20.2, Revision 0 Generators From Diesel Generator Rooms System Operating Procedure Portable Ventilation 3/31/89 2.2.38.1, Revision 5 System Abnormal Procedure Control Building 3/31/89 2.4.8.4.9, Revision 9 Temperature Above or Below Temperature Limits Emergency Procedure Postfire Operational 7/2/89 5.4.3.1, Revision 5 Information Emersency Procedure Postfire Shutdown to 6/10/89 5.4.3.2, Revision 5 Cold Shutdown Outside Control Room The inspectors reviewed Emergency Procedures 5.4.3.1 and 5.4.3.2 for reactor shutdown to cold conditions af ter a fire which requires control room evacuation and the use of the alternate shutdown panels.
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-7 In connection with the procedures reviewed, the operators were asked'to perform a drill which assumed a fire in the control room which required control room evacuation and a loss of offsite power.. The drill comenced with the operators' simulating tripping the reactor in the control room. All other actions were simulated'outside the control room. 'It was observed that various operations were accounted for, such as, manual startup, of Diesel Generator 2 (DG-2), unloading and loading of the critical switchgear for energizing the 4160V and 480V Busses, energizing Service Water Pumps 1B and ID and RHR Pump D,-manually aligning service water valves, and actuation of'480V Breakers MCC-S and MCC-Tx. System Operating Procedure 2.2.20.2, for startup of the diesel generator- (DG-2), was used during the exercise. The
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procedures complemented the operator knowledge and training of
'the operation of those systems.
It was noted by the inspectors that Attachment H to Emergency-Procedure 5.4.3.2. incorporates a feature which requires the use of jumpers to energize three atmospheric dump valves while the-reactor is in transition from hot shutdown to cold shutdown
.(approximate' reactor pressure of 450 to 400 psig). The inspectors observed that a human factors review was indicated since it was not obvious that the installation of the jumpers enuld be achieved in a satisfactory manner. The licensee agreed to review this aspect of the postfire safe shutdown procedure to confirm the feasibility of the installation.
(2) Licensed Operator Requalification Program for Abnormal Procedures (Fire Protection Related)
The inspectors reviewed the documentation for reactor operator requalification training for 1988 on emergency and abnormal procedures. This training requires that each reactor operator and senior reactor operator review the contents'of all emergency and abnormal operating procedures on an annual basis and maintain current training on'the alternate shutdown panel and the isolation panel.
The reactor operators and senior reactor operators have had requalification training for 1988 in the performance of Emergency Procedure 5.4.3.2 and demonstrated their knowledge of its use in a satisfactory manner during the drill discussed above. On the basis of this review, the inspectors found the licensed operator recualification to be adequate.
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(3) Damage Control Measures
(a) Appendix R,Section III.L.5 requires that fire protection features be incorporated in the design of structures, systems, and components important for safe shutdown. The
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design must also be capable of limiting fire damage so that systems necessary to achieve and maintain cold shutdown are free of fire damage or can be repaired such that the equipment can be made operable and cold shutdown achieved within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Materials for such repairs are required to be readily available onsite and procedures are to be in effect to implement such repairs.
If the fire is. in'.the auxiliary relay room, motor control center MCC-Tx may be damaged, resulting in loss of power to Battery Charger B and the battery room exhaust fan.
Emergency Procedure 5.4.3.1, includes a section for making this repair and provides information on the location of the repair materials in the warehouse. This repair is not necessary during hot shutdown, but may.be required during cold shutdown in order to recharge Battery B.
This repair may also be necessary for a fire in the cable expansion room.or the reactor building.
Cables to diesel fuel oil transfer Pumps A or B could be damaged by.a fire in the southeast side of the reactor building. This is also a cold shutdown repair. The material is stored in the warehouse and procedures (Emergency. Procedures-5.4.3.1 and 5.4.3.2) are available to perform the actionsiif necessary.
On the basis of the review, the inspectors found these procedures to be adequate.
(b) Abnormal Ambient Conditions During postfire safe shutdown conditions, the ambient temperatures in Station Battery Rooms IA and IB may exceed 115'F. The temperatures in the critical DC Switchgear Rooms 1A and IB may exceed 104"F at the time of the fire.
Two dedicated portable exhaust fans are available to ventilate each of the above areas. System Operating Procedure 2.2.38.1, provides information relative to the availability of the fans, cables, and other devices necessary to complete electrical hookup of the fans.
The fans, ducting, welding cable, and disconnects were verified in their various storage locations by the inspectors and found to be acceptable.
No violations or deviations were identified.
c.
Associated Circuits Review l
The associated circuits analysis, dated April 1986, provided the
basis of the modifications made to comply with 10 CFR 50. Appendix R.
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This analysis was' developed by a contractor to the licensee.
(Engineering, Planning, and Management (EPM)). The licensee presented the following calculations which demonstrated that this program is updated and.kept current:
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P-335 El 6688-025, dated March 28, 1988, "Results of Database-Separation Analysis" (Separation Criteria for. Reactor Vessel Level)
P-335 EL 6688-026, dated April 15, 1988, " Compliance of Swing l
Battery Charger with the Separation Requirements of 10 CFR 50, Appendix R" P-335 El 6688-003, dated May 12. 1988, "Results of Database-
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Separation Analysis" (Separation. Criteria for Reactor Vessel Level)
P-186 El 6686-025,'" Spurious Operation-of RHR Pump Breakers" The inspectors concluded that the licensee's analysis of associated circuit concerns is satisfactory and met the requirements of Appendix R Section III.L.
No violations or deviations were identified in the area of associated circuits review.
d.
Fire Barrier Penetrations The licensee's tracking system for fire barrier penetration seals was reviewed to ensure that the seals have been maintained to provide separation between redundant trains of safe shutdown equipment as required by Section'III.G of Appendix R.
A number of penetrations were selected for field verification to verify that the penetrations were-sealed as specified on plant drawings and that adequate documentation was available to confim the fire rating of the seal.
The follow...g documents were reviewed:
Maintenance Work Request 84-0149, dated January 18,1984, " Fire
Barrier Penetrations, Various Areas" Calculation 0840-045-603, Revision 1. " Grouted Penetration
Seals" Calculation 0840-045-C05, Revision 1, " Silicone foam Pipe and
Conduit Penetrations" Calculation 0840-045-006, Revision 1, " Silicone Foam Duct
Penetrations" Calculation 0840-045-C07, " Pipe / Duct Sealed with Grout or Foam
and Sheet Metal Plate"
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' Drawing CNS-FP-143, Revision 1. " Fire Area Boundary Drawing,
Critical Switchgear Room IF, South Wall, 932 Feet, 6 Inches, Reactor Building" o
' Drawing'CNS-FP-171, Revision 1. " Fire Area Boundary Drawing,
Diesel Generator Room
'2', North Wall" Report WHI-0495-PSV-0458, " Report of the Fire Test of a Fire Stopping Method for Through Penetrations in a Nine (9) Inch Thick Concrete Slab Using Nine (9) Inch Thick Dow Corning 3-6538 S*licone foam" Based on the review of the above documentation, the inspectors found that the licensee has developed a fire barrier tracking system which enrures that required fire barrier penetration seals are adequately maintained. Additionally, for all penetration seals reviewed during the field walkdown sufficitot fire test documentation was available to confirm the requisite fire rating.
No violations or deviations were identified in the area of penetration seals, e.
Emergency Lighting The inspectors reviewed the adequacy of the installed emergency lighting required by Section III.J of Appendix R.
The lighting was reviewed to ensure that it was adequate to provide the necessary illumination of ingress and egress paths for shutdown personnel and that there would be adequate light to perform any manual ections necessary to achieve safe shutdown.
In addition, lights were inspected in the field to ensure that they have been adequately surveilled and maintained. Several completed procedures were reviewed to confirm that the procedures were being implemented as required.
No violations or deviations were identified in the area of emergency lighting.
A f.
Review of Engineering Evaluation _s.
The inspectors reviewed the following engineering evaluations prepared by the licensee in accordance with Generic Letter 86-10
" Implementation of Fire Protection Requirements," to ensure that they did not have any impact on the approved fire protection programs:
P253 EL6687-083 " Evaluation of Combustible Leading on Fire
Barrier Exemptions," dated July 20, 1989 P335, EL6687-006, " Clarification of Exemption Requests Originally Approved in September 1983 SER." dated May 11, 1987
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-11-P253,EL6687-038,"VentDuct(Pipe)ThroughCableSpreadingRoom l
Floor at 918 Feet, Elevation of the Control Room," dated i
April 15, 1987 P253. EL6686-062, " Fire Damper and Wall Opening Between DC
Switchgear Room 1B and the Corridor at 903 Feet, Elevation of the Control Building," dated April 15, 1986 P232. ED6685-006, " Fire Barrier Analysis, Critical Switchgear Room 1F (Fire Zone 3A) to Controlled Corridor (Fire Zone 198),
Elevation 932 Feet, Fire Door R208," dated November 1, 1985 P232, ED6685-006, " Fire Door Evaluation, Critical Switchgear
Room 1G to Exterior. Elevation 932 Feet, Fire Door R210" P232 ED6685-006, " Fire Door Evaluation, Auxiliary Relay Room
(Fire Zone 8A) to Control Building Corridor (Fire Zone 80)
Elevation 903 Feet, Fire Door H104" P232 ED6685-006, " Fire Door Evaluation. Diesel Generator Room 1A
(Fire Zone 14A) to Turbine Building Mezzanine (Fire Zone 120),
Elevation 903 Feet, Fire Door N103" On the basis of the review, the inspectors found each of the above engineering evaluations to be technically sound and not to impact the compliance with the approved fire protection program.
No violations or deviations were identified in the areas of engineering evaluations, g..
Approved Exemption Recuests In a Safety Evaluation Report (SER) dated September 21, 1983, exemptions from the requirements of Appendix R were granted for the following areas:
Service Water Intake Structure
Cable Spreading Room Cable Expansion Room
Recctor Building Northeast Corner Room
Control Building Basement Auxiliary Relay Room Control Room Fire Area Boundaries
The above areas were inspected to ensure that the level of fire protection provided were as described in the exemption reauest. The i
level of protection provided was found to be acceptable and as described except for the Service Water intake Strccture.
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By letter dated June 28, 1982, the licensee comitted to provide a full automatic suppression system for the service water intake
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structure, including wet pipe sprinkler system protection throughout the area. On the basis of that comitment, the NRC granted an exemption request for the area from the requirements of Appendix R.
Section III.G.
. Subsequent to the SER, the licensee determined that a Halon fire suppression system for the area was a more desirable means of automatic fire suppression. While the use of Halon is an acceptable substitute, the. licensee did not inform the NRC of the modification to.their commitment.- The licensee was informed that this was an e
apparent deviation from this comitment which was dated June 28,-
1982. The' inspectors concluded that the issue was the licensee's failure to track comitments accurately.
Deviation (298/8924-01):
Failure to notify NRC of a comitment change to a fire protection suppression. system.
3.
Fire Protection / Prevention Program (64704)
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This part of the inspection was' conducted to determine if the licensee ~had established and was implementing a program for fire protection and prevention in confomance with regulatory requirements, Technical Specifications, and industry 9uides and standards.
a.-
Procedure Review The inspectors reviewed the following procedures:
0.23. "CNS Fire Protection Plan," Revision 8. dated July 20,
1989 0.7, " Hazardous Material Control," Revision 4, dated April 30,
1987 0.7.1, " Control of Transient Combustibles," Revision 2. dated
April 7, 1988 0.6. " Personnel Safety," Revision 6, dated June 8, 1989
0.16 " Control of Fire Doors," Revision 8, dated February 23,
1989 2.2.30. " Fire Protection System," Revision 31, dated March 9,
1989 2.2.72, " Smoke, Temperature, and Flame Detection " Revision 6,
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dated February 20, 1989 5.4.1, " General Fire Procedure," Revision 23, dated August 11,
1988
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This procedure review verified that the licensee had technically adequate procedures to implement the fire protection program. The licensee's program provides for the control of combustible materials and housekeeping for reduction of fire hazards.. Administrative
. controls have been established to handle disarmed or' inoperable fire detection or suppression systems; provide for maintenance and surveillance on fire suppression, detection, and emergency 1.ighting; establish personnel fire fighting qualifications, training and fire protection staff responsibilities; provide fire emergency personnel designations, as well as plans and actions; and establish controls for welding, cutting, grinding, and other ignition sources.
b.
Plant Walkdown I
The inspectors conducted a walkdown of the fire main and verified that it was operable-as required by Technical Specifications. This verification included the fire pump house with both the electrical and diesel fire pumps.
A tour of accessible areas of the plant was conducted to assess general area conditior,s, work activities in progress, and the visual
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condition of fire protection systems and equipment. Combustible materials and flammable and combustible liquid ano gas usage were restricted or properly controlled in areas containing safety-related equipment and components. Items checked included positions of selected suppression system valves; fire barrier conditions; hose stations; hose houses; carbon dioxide and Halon system lineups; fire lockers; and fire extinguishers for type, location, and condition.
Adequate portable fire extinguishers were provided at designated places in each fire zone. Fire brigade equipment, including emergency breathing' apparatus, was found to be properly stored and maintained.
Access to fire suppression devices was not.found to be restricted by any materials or equipment in all areas except the control room.
In the control room, one wall mounted pressurized water extinguisher was found obstructed by a portable drawing rack. The licensee's representative took steps to correct this problem. A subsequent review of the surveillance test for fire extinguishers identified the lack of a specific attribute in the procedure for accessibility.- When this deficiency was identified to the licensee, the procedure was revised and was in review for issue at the conclusion of this inspection.
There were no construction activities in progress in the toured areas. There was some maintenance work and surveillance testing noted. General housekeeping conditions were found to be very good.
c.
Surveillar.ce Test Review The inspectors selected and reviewed the following completed surveillance tests for the last two test cycles:
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'! Fire Protection System Annual Inspection"
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6.4.5.6, " Fire Detection System Circuitry Operability"
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'6.4.5.9
" Diesel Fire Pump Inspection"
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6.4.5.14. "High Pressure CO2 Bottle' Inspection"
6.4.5.16.1, " Fire Damper Assembly: Inspection"
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6.4.5.16.2, " Fire Area Barrier Visual Inspection"
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6.4.5.16.3, _" Fire Area Barrier Fire Penetration Seals Visual
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-Inspection" 6.4.5.17 " Fire Fighting Equipment Monthly Inspection"
6.4.5.19, "Halon 1301 Service Water Pump Room"
6.3.13.2, " Safe Shutdown Emergency Lighting Functional Test"
This review ~ verified that the fire protection systems and equipment'
installed for the protection of safety-related areas were functional and tested in accordance with the requirements specified in the Technical Specifications, d.
Interviews / Records Review / Fire Drill The inspectors also reviewed fire brigade training and drill records.
The records were in order and confirmed that training and drills were being conducted at the specified intervals. Three licensee personnel, designated as qualified fire watches were interviewed to determine their knowledge of their duties, responsibilities, and required actions. The interview results were considered satisfactory.
Fire brigade response and conduct were observed by the inspectors during a drill conducted by the licensee. Comments on the response and performance were discussed with licensee representatives. There were no significant deficiencies noted.
e.
Fire Protection Audit
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The last annual quality assurance and triennial independent audits were reviewed by the inspectors. System and equipment alterations, tests, surveillance, maintenance, records, and overall program
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procedures were addressed. Discrepancies identified were fonnally presented to the affected organization. Responses were tracked to closecut, and actions taken were reviewed for adequacy. The audit l
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~ documents satisfied the comitments of. CNS relating to the fire protection program quality assurance audits. A program is in place for dealing with nonconfonning conditions.
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There were no violations or deviations identified in this area of the I
inspection.
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'4 Exit Meeting An exit meeting was held August 4, 1989, with the personnel indicated in paragraph 1 of this report. At this meeting, the scope of the inspection and the findings were sumarized. The li::ensee did not identify as proprietary any of the information provided to or reviewed by the-inspectors.
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