IR 05000373/1999013
| ML20211F912 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 08/25/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20211F878 | List: |
| References | |
| 50-373-99-13, 50-374-99-13, NUDOCS 9908310102 | |
| Download: ML20211F912 (12) | |
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U.S. NUCLEAR REGULATORY COMMISSION l
REGION 111 l-Docket Nos:
50-373;50-374 l
License Nos:
50-373/99013(DRS); 50-374/99013(DRS)
Licensee:
Commonwealth Edison Company (Comed)
Facility:
LaSalle Nuclear Generating Station, Units 1 and 2 l
Location:
2605 N. 21 Road Marseilles, IL. 51341-9756
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Dates:
August 4-6 and 9-11,1999 Inspector:
D. Schrum, Reactor Engineer
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Approved by:
John M. Jacobson, Chief, Mechanical Engineering Division of Reactor Safety 9908310102 990825 PDR ADOCK 05000373 G
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l EXECUTIVE SUMMARY LaSalle Nuclear Generating Station, Units 1 and 2 NRC Inspection Report 50-373/99013(DRS); 50-374/99013(DRS)
This routine, announced inspection assessed the effectiveness of the licensee's fire protection program. The following strengths and concerns were identified:
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There were a low number of plant fires since January 1998 (Section F1).
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The control of transient combustibles in the plant was excellent (Section F1 and F2).
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The low number of fire protection impairments requiring a fire watch was a program
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strength (Section F2).
Most fire protection equipment was well maintained (Section F2).
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The 10 CFR 50.59 screenings and evaluations for fire protection program changes were
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thorough and had addressed safety issues (Section F3).
The fire protection surveillance program was wellimplemented (Section F3).
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The fire protection staff was experienced and knowledgeable, and proactive in dealing
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with plant problems (Section F4).
Most fire protection problems were identified and corrected (Section F4).
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The fire brigade performance during a fire brigade drill was good (Section F5).
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A recent fire protection self assessment identified most fire protection program problems
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prior to this inspection (Section F7).
j Two inspector concems were noted: (1) The offsite fire department had not
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participated in fire brigade drill in two years when these drills should be performed annually. (2) Emergency lighting units (ELUs) had been (a)1 in the maintenance rule for two years and not all of the ELU functional failures had been identified (Section F2).
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Report Details l
IV. Plant Support F1 Control of Fire Protection Activities a.
Inspection Scoce (64704)
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The inspector reviewed the fire reports from January 1998 to August 1999. The control of the fire brigade drill, equipment repairs, and combustibles was evaluated.
b.
Observations and Findinas A review of fire reports indicated that there were three insignificant fires during the above period of time. This low number of fires indicated good fire prevention practices, including hot work controls, and good transient combustible controls in the plant. The licensee conducted an investigation with assigned corrective actions to prevent recurrence of the fire.
The inspector noted that the fire brigade drill conducted during this inspection was well managed. The fire brigade drill scenario was realistic and appropriately prepared the fire brigade staff for a real fire. The fire protection staff's involvement to ensure timely repairs to fire protection equipment and barriers contributed to a low number of impairments requiring a fire watch.
c.
Conclusions The low number of plant fires indicated that fire prevention controls were appropriately implemented. The fire brigade drill was well managed. The licensee was effective in maintaining a low number of fire impairments. Overall, the fire protection program was well managed.
F2 Status of Fire Protection Facilities and Equipment a.
Inspection Scope The inspector toured the turbine, reactor, and auxiliary buildings to observe the adequacy and control of combustibles and the material condition of dampers, fire barriers, fire doors, hose stations, fire brigade equipment, detection equipment, extinguishers, sprinkler systems, and emergency lights. The inspector reviewed fire protection equipment surveillances and equipment history.
b.
Observations and Findinos The material condition of most fire protection equipment was observed to be in good condition. Surveillances and equipment history also indicated that most fire protection j
equipment condition was good, except for emergency lighting. The backlog of open fire protection deficiencies and impairments requiring a fire watch was low. Most fire doors in the plant were in excellent condition which included self-closure and latching. The
licensee had identified some doors with the outer steel of the door detached from the interior supports of doors. These doors had been evaluated as meeting their design
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requirements and had been scheduled for replacement. Extinguishers had been
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inspected and had a current inspection date. The fire fighting equipment was in good condition and well organized. The fire brigade dress-out areas contained proper turnout gear and were well controlled.
Surveillances indicated that emergency lighting units (ELUs) were having a substantial l
I number of failures. The licensee stated that ELUs had been in a(1) of the Maintenance Rule for nearly two years. The inspector noted that Problem Identification Forms (PlFs)
had not been issued for some of the ELU failures. The licensee stated they had previously identified this problem during a recent self-assessment of the fire protection program. Corrective actions had not been completed so the licensee did not know the current failure rate for the ELUs. The license stated that they were planning additional corrective actions to reduce the ELU failure rate.
During the time period from June 6,1998, through July 20,1998, the licensee identified i
two failed penetration seals while performing Surveillance, LTS-1000-41, " Electrical Fire Penetration inspection," Revision 4. However, the licensee also identified 10 failed penetrations in Unit 1 and 10 failed penetrations in Unit 2 that were not included in the surveillance. The licensee stated that the gypsum penetration seals were crumbling from water damage. An additional 10 percent of the penetration seals were inspected, during the above time period, as required by Administrative Technical Requirements (ATR) 4.7.6.1(c), because of the two failed penetration seals. No additional problems were identified during this 10 percent sample of penetrations. A scheduled surveillance was performed following this inspection and did not identify any additional failed
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penetrations. The inspector agreed that the surveillances had bounded the problem of water damage to these type of penetration seals. The inspector did not identify any additional failed penetrations during the plant tour.
Control of combustibles was good with few transient combustibles in the plant. The cleanliness and housekeeping in the plant were excellent. Items that were not needed were removed from the plant. Flammable liquids were appropriately stored in fire proof cabinets and safety cans. There was a minimal amount of oil below rotating equipment.
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Conclusions The material condition of most fire protection equipment appeared to be good. The plant was clean and housekeeping was excellent. Control of combustible materialin the plant was good. There were a low number of fire protection impairments that required a fire watch for compensatory actions. Corrective actions for penetration seal problems were appropriate. Corrective actions for ELUs were not yet fully implemented.
l F3 Fire Protection Procedures and Documentation a.
Inspection Scope Fire protection surveillances were reviewed for completeness, accuracy, procedure compliance, and equipment condition. The inspectors reviewed 10 CFR 50.59 screenings and evaluations for changes to the fire protection program.
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Observations and Findinas The surveil!ances reviewed were on time, complete, and thorough. Procedural compliance was good.
l The inspector reviewed the 10 CFR 50.59 screenings and 10 CFR 50.59 evaluations for changes in the fire protection program. The screenings and evaluations were appropriately performed, thorough and had addressed safety concerns. The evaluations adequately addressed the effects of the proposed changes on plant operations, interactions with other systems and components, any new failure modes, the effects on accidents and transients, and whether prior NRC review was required.
Evaluations performed for plant changes appropriately answered the 10 CFR 50.59 questions with thorough in-depth discussions, referencing other documents as appropriate. The screenings and evaluations included removing fire protection NRC reporting requirements from the ATRs, changing the fire detector surveillance frequency from six months to 12 months, justifying a change from a continuous fire watch to an hourly fire watch for impairments in the diesel corridor (ATR 3.7.5.2), and adding a smoke detector. The evaluation for changing the detector surveillance frequency included a failure history for fire detectors in the plant. The licensee determined that the smoke detectors are highly reliable with a very low failure rate, so the extension of
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the surveillance should have little effect on the increase in risk from fires. Changing
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requirements from a continuous to an hourly fire watch was consistent with other compensatory measures for impairments of this type.
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Conclusions Surveillances had been performed per procedural requirements and were on time. The 10 CFR 50.59 evaluations and screenings were effective, thorough and appropriate to the plant changes.
F4 Fire Protection Staff Knowledge and Performance a.
Insoection Scope The inspector reviewed approximately 20 Problem identification Forms ( PlFs) in detail to determine the licensee's effectiveness in identifying, resolving, and preventing fire protection problems. The inspector interviewed fire protection and engineering personnel concerning the PlFs to understand the extent of their involvement in the fire protection program.
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Observations and Findinas A detailed review of the PlFs indicated that there was a good description of the problem and corrective actions were appropriate for the significance of the problems. There was excellent fire protection staff and engineering staff involvement for assessing technical issues. Evaluations performed for fire protection problems were thorough and detailed.
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Conclusions j
I The inspector concluded that the actions taken once a problem was identified were j
indicative of a good corrective action program. The majority of plant problems had been l
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identified and assessed, and had corrective actions assigned. The inspector concluded that the licensee staff was experienced, knowledgeable and competent regarding the issues being addressed.
F5 Fire Protection Staff Training and Qualification a.
Inspection Scope The inspectors reviewed fire brigade training, qualification records, and fire brigade critiques.
On August 9,1999, the inspector observed a fire brigade drill for a fire in a cable tray in the Reactor Building and the subsequent critique meeting. The inspector reviewed the drill scenario prior to the drill. In addition, the inspector reviewed fire brigade training and qualification records.
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Findinas and Observations Training records indicated that the fire brigade members, for those members listed as qualified, had received required quarterly classroom training. Live fire training for all brigade members was being conducted on an annual bases. The critiques for fire brigade drills were thorough and identified both strengths and weaknesses. The licensee gave training in the weak areas to improve brigade performance. One area of concern was that fire brigade drills with the off-site fire department had not been performed in two years when these drills should be performed annually, if possible, according to Branch Technical Position 9.5-1. The licensee stated that they had rescheduled this drill for September.
The inspectors observed a fire brigade drillin the reactor building. The fire brigade leader provided an early response to investigate the simulated cable tray fire. Five fire brigade members responded in a timely manner to the simulated fire with appropriate fire fighting gear and completed dressing for entering the space. The pre-fire plans were appropriately used to identify the risks and determine conditions in the fire area.
The team members exhibited good team work by checking each other's equipment.
Two brigade members entered the fire area with dry chemical extinguishers. The brigade leader exhibited good command and control of the brigade members. The fire brigade leader contacted the control room to secure the electrical supplies in the cable tray. When dry chemicals were not effective in putting out the fire the fire brigade used fire hoses to put out the fire.
A critique was held at the end of the fire brigade drill. The fire brigade members were all owed to give their insights on what they considered as problems during the drill. The fire drill evaluators stated that the fire brigade performance was excellent. They also stated that the brigade should have been more timely with the use of fire hoses when the dry chemicals were not effective.
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Conclusions The fire brigade training program was effective. The fire brigade performance during a fire brigade drill was good. Fire brigade critiques were detailed and through. Training requirements were met and training records were complete.
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F7 Quality Assurance in Fire Protection Activities a.
Inspection Scope The inspector reviewed fire protection audits and self-assessments of the fire protection j
program.
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Observations and Findinas Five members of fire protection staff performed a one week in depth assessment of the fire protection program just prior to this inspection. The assessment did not identify any significant problems in the fire protection program. The planned corrective actions for those problems identified appeared to be appropriate. The issues identified by the inspector had been previously identified by this assessment. A review of fire protection audits indicated that adequate resources were devoted to identify fire protection problems.
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Conclusions The inspector concluded that the licensee's self assessment process had effectively identified the fire protection program problems prior to the NRC's inspection. The inspector considered the quality assurance and self assessment activities for the fire protection program to be pro-active, thorough, and effective.
F8 Miscellaneous Fire Protection issues F8.1 (Closed) IFl 50-373/374-97011-08: The licensee identified a problem with the fuel inventory and piece count procedure in that it did not require documentation of the visual configuration of disassembled or partialitems that were not contained in a sealed container. This item was issued because the licensee had not relocated fuel pins or initiated actions to identify loose fuel pellets. This problem is included in the licensee corrective action process. This item is closed.
V. Management Meetings X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management and staff at the conclusion of the inspection on August 11,1999. The licensee acknowledged the findings presented and identified no proprietary information.
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PARTIAL LIST OF PERSONS CONTACTED J. Barm, Design Engineer-J. Benjamin, Site Vice President S. Chinga, Fire Protection Engineer B. Collins, Fire Marshal D. Farr, Operations Manager V. Gengler, Security Supervisor F. Gogliotti, Design Engineering Supervisor C. Howland, Radiation Protection Manager J. Kodrick, Maintenance Staff J. Meister, Station Manager D. Mefford, Assistant Fire Marshal J. Poitock, Engineering Program Supervisor D. Roberts, Fire Protection Engineer F. Spangenberg, Regulatory Assurance Manager R. Stachniak, Nuclear Oversight Assessment Manager R. Vickers, Fire Protection System Engineer INSPECTION PROCEDURES USED IP 64704:
Fire Protection ITEMS OPENED, CLOSED, AND DISCUSSED Opened None Closed 50-373/374-97011-08 IFl Review licensee's corrective actions for potentially missing fuel and idantification of loose fuel Discussed None
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l LIST OF ACRONYMS USED
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Administrative Technical Requirements Comed Commonwealth Edison Company
'ELU Emergency Lighting Unit'-
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Inspection Follow up item PlF '
Problem Identification Form i
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. PARTIAL LIST OF DOCUMENTS REVIEWED 10 CFR 50.59 Safety Evaluation, * Fire Detection instrumentation increase Frequency of Operable From 6 Months to 12 Months," OSR Number: 99-033 LaSalle Administrative Technical Requirements 10 CFR 50.59 Safety Screening, Administrative Technical Requirements Amendment 29, OSR Number: 99-342 10 CFR 50.59 Safety Evaluation, Design Change Package No. 9700101 10 CFR 50.59 Screening, ATRs, Amendment 22, OSR Number: 98-1060," Limiting Conditions of Operation for Appendix R Emergency Lights" 10 CFR 50.59 Safety Screening, OSR 98-672, " Fire Protection Technical Specifications moved
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to ATRs."
OE98006, Operability Screening for PlF#1998-00771 System Support Chemistry Report on Smoke Detector Test Gas - From Byron Station (A98-0082)
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Transco Fire Test Report No. TR-207, Revision 1 PIF#L1998-00771, Q&SA Notes inconsistency Between Electrical Fire Stop Justification and UFSAR Cable Descriptions PlF#1997-07131, Exceeded FP Tech Spec Time Clock for Fire Doors PlF#1997-04027, Fire Watch Resources Called in on Saturday for Continuous Fire Watch PIF#1998-01073, Q&SA Has identified Byron NON on Test Smoke - Coded as Sl#492807 PlF#1998-01183, O&SA Has identified Byron OPEX for Fire Brigade Medical Qualifications PlF#1998-0459, Deficiency in Gypsum Sealin Secondary Containment PlF#1998-04247, Degradation of Gypsum Seals in Turbine-Auxiliary Building Wall
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PlF#1998-04759, Deficiency in Gypsum Seal in Secondary Containment
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PIF#1998-0816, Empty Sleeves That Pass Through Penetration Seals in Control Room PIF#1998-03425, Unit 1TB Fire Sump Header Appears to be Corroded PlF#1998-06130, Failure of Drop Test on Roll up Doors in AEER PlF#1998-06979, Opening Found in Fire Rated Barrier in the U1, Div.1,250VDC Battery Room
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PlF#1999-03604, Record Storage Vault Ventilation Damper Electro - Thermal Links Found Blown PlF#1999-03673, PIFs Not Always Generated For Appendix R DC Emergency Light Failures PIF#1999-03625, Minor Errors and/or inconsistencies in ATRs PIF#1999-03522, Off-site Fire Drill Canceled Due to a Fire in Marseilles LTS-1000-41, * Electrical Fire Penetration inspection," Surveillance Results For: July 95, November 95, February 96, March 97, and July 98 LaSalle County Nuclear Station Pre - Fire Plans LES-DC-107, "DC Emergency Light 8 Hour Discharge Test," Surveillance Results For:
February 98, March 98, May 98, August 98, October 98, December 98, January 99, February 99, February 99, March 99, April 99, and May 99 List of Open Work Requests, dated July 2,1999 and August 4,1999 Procedure #LTS-1000-14. " Inspection of Fire Doors Separating Safety Related Fire Areas" Surveillance Results For: January 99 Appendix R Emergency DC Lighting Maintenance Rule Performance Criteria Diesel Fire Pumps Maintenance Rule Performance Criteria Fire Drill Scenario No. 2 NRC Information Notice No. 89-52, " Potential Fire Damper Operational Problems"
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List of Fire Protection Engineering Requests, dated July 2,1999 List of Transient Combustibles, dated July 1999 Procedure LTS-1000-36, " Fire Damper Visual Inspection," Surveillance Dated: December 98 D. Roberts Memo, * Minor Fire Door Maintenance Deficiencies," dated December 11,1997 LMS-ZZ-03," Inspection of Fire Doors Separating Safety Related Fire Areas," Revision 1 LAP-900-16, " Fire Protection impairments," Revision 14 LES-FP-05,"lonization Fire Detector Test," Surveillance Results dated: December 98 Diesel Fire Pump Maintenance Rule Evaluation History From January 97 to June 99 Diesel Fire Pump OOS List December 94 to May 99 Diesel Fire Pump Performance Monitoring for Availability
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List of ELU Failures for 18 Months
LMS-FP-21 " Extinguisher and Hose Station Check," Surveillance For: June 99
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Fire Drill Critiques, dated June 97 to June 99 Fire Watch Logs from June 23,1999 to June 30,1999 LAP-900-17, " Fire Brigade Quarterly Review," Surveillances for January 98, April 98, July 98, January 99, April 99, and July 99 LaSalle County Station Fire Protection Self-Assessment, dated July 30,1999 LER 98-006," Local Fire Detection Module in the Standby Gas Treatment System Located in a Harsh Environment" LER 98-008, * Fire Protection Valves Not Tested Per Technical Specifications" List of Fire Protection Temporary Alterations, dated July 99 Marseilles Fire Protection District Training Record UFSAR Fire Area / Zone Locations Nuclear Oversight Assessment NOA-01-99-024, Fire Protections, dated March 99 Fire Protection Program Audit Report, Comed-98-01 UFSAR Appendix H, Fire Hazards Analysis List of Fire Protection PlFs from June 97 to June 99
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