IR 05000409/1985013

Insp Rept 50-409/85-13 on 850708-11,0820 & 30.Violation Noted:Failure to Hydrostatically Test Fire Extinguishers

ML20135H771
Person / Time
Site:	La Crosse File:Dairyland Power Cooperative icon.png
Issue date:	09/18/1985
From:	Guldemond W, Holmes J, Mendez R, Ulie J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20135H768	List: IR 05000409/1985013 ML20135H767 ML20135H769
References
50-409-85-13, NUDOCS 8509240211
Download: ML20135H771 (21)

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U.S. NUCLEAR REGULATORY COMMISSION REGION III-

Report No. 50-409/85013(DRS)

Docket No. 50-409' License No. OPR-45 Licensee: Dairyland Power Cooperative 2615 East. Avenue - South Lacrosse, Wisconsin 54601 Facility Name: Lacrosse Boiling Water Reactor Inspection At: Lacrosse Site, Genoa, Wisconsin Inspection Conducted:' . July 8-11, August 20 and August 30, 1985 Inspectors: J. Holmes 9-lB-SI

\,M Date M'bf// w . Mendez 1-/8-8f Date'

%.UEL Q J. Ulie 9-12-85 Date-Approved By: . G. Guld d,-Chief 9 s'

Operation Programs Section Date'

Inspection Summary Inspection on July 8-August 30, 1985 (Report No. 50-409/85013(DRS))

Areas Inspected: Special Safety inspection conducted to verify the adequacy of_the facility's post fire safe shutdown method, a review of License Condi_ tion 2.c(4) on fire protection modifications, and other fire protection features. The inspection involved 144 inspector-hours by three NRC inspectors i and -two NRC consultants including 6 inspector-hours onsite during off-shifts.

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, Results: _Of the nine areas inspected, no violations or deviations were identified in eight areas; one violation (failure to hyrostatically test fire extinguishers - Paragraph 10) was identified in the remaining are PDR ADOCK 05000409 s G .PDR

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DETAILS 1. Persons Contacted Dairyland Power Cooperative

• S. Buck, Senior Reactor Operator

• R. Christians, Technical Support Engineer

• G. Joseph, Security Supervisor

• J. Parkyn, Superintendent

• M. Polsean, Fire Protection Supervisor

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• D. Rybarik, Mechanical Engineer

• B. Wery, Quality Assurance Supervisor

US NRC

, *R. Du'dley, Project Manager, NRR

• W. Guldemond, Chief, 0perational Programs Section, Region III

• W. Paulson, Project Manager, NRR

• Denotes persons attending the exit meeting of July 11,- 1985.-

2. Post Fire Shutdown Capability The Lacrosse Boiling Water Reactor (LACBWR) was originally constructed

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as a Pilot Plant containing diverse systems for safety, but not redundant systems. The plant uses a shutdown condenser for establishing hot

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shutdown, and an overhead storage tank for~ achieving cold shutdown which makes it possible to shut down the plant without the use of

. pumps or motive powe If a fire occurs in the control room or cable spreading area, shutdown can be accomplished without reliance on

electric power for control or instrumentatio In this case, only DC power.would be needed for emergency lighting which.is available from individual battery units. These features provide an alternative

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shutdown path for fire in any area of the plant, and thereby meet the

, requirements of Appendix Systems Required for Safe Shutdown-The Reactor Protection System and the following diverse systems are provided for safe shutdow . ' Shutdown Condenser

. High. Pressure Core Spra . Alternate Core Spray (Low Pressure)

. Manual Depressurization System

. Decay Heat System-

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._ Decay Heat Blowdown to Main Condenser

. Main Condenser-These systems are not redundant (i.e.,-there are not two separate shutdown condensers, or two Decay Heat Systems), but are configured

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in such a manner so that at least one or more systems will be available to achieve hot shutdown in the event of fire in any location within the plan Reactivity Control Upon detection of a disabling fire, the control rods will be inserted using the scram switch in the control room, or will automatically be inserted by the Reactor Protection System (RPS)

upon loss of off-site power. If neither of these actions occur, scram can be accomplished by opening breakers for all 29 rods in Reactor Building Motor Control Center (RBMCC) 1A and/or placing the scram switch on RMBCC1A in the scram position. Thus, this method of reactivity control meets the requirements of Appendix Reactor Coolant Inventory Control and Decay Heat Removal For. all fire areas, one method is available for accomplishing both inventory control and decay heat removal. The shutdown condenser removes heat from the reactor coolant by condensing steam and returning condensate to the. reactor vessel. This method allows for maintaining the reactor water inventory. The only change in reactor vessel water level will be due to water contraction coincident with the reduction in temperature. Decay heat is transferred to the atmosphere by boiling water on the shell side of the shutdown condenser. This water is provided by either the diesel powered Alternate Core Spray pumps, or the Emergency Service Water Standby Syste Process Monitoring In an event of control room evacuation, the following instrumentation is available inside containment from direct reading gauges:

. Reactor Pressure

. Reactor Level

. Shutdown Condenser Level (Shell Side)

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Neutron Monitor (Low Level - Hand Held Instrumentation)

The shutdown coiJenser platform is the remote control area where the reactor pressure and shutdown . condenser level are used to monitor the cooldown rate in events requiring evacuation'of the control room or fire damage to the electrical equipment roo Should a fire occur in the containment building, it is possible to lose indication of reactor pressure and shutdown condenser leve The reactor pressure can be deduced from the hot leg temperature which is within a few degrees of reactor average temperature since

. design studies have shown as much as.30% flow in the recirculation-loop is due to natural circulation. There is no redundant shutdown condenser level indication and should a fire occur in the containment building, the shutdown level indication may be los ..

During the inspection the licensee agreed to install a new and independent shutdown condenser level indicator. This is considered an Open Item (409/85013-01(DRS)) pending Regior. III's verification of this installatio e. Support Systems and Equipment The only support systems required for achieving hot shutdown using the shutdown condenser are as follows:

. Diesel powered ACS pumps or the ESWSS pumps for secondary side water supply

. 125V DC batteries and 120V AC inverters for instrumentation and valve control The diesels are only required when the HPCS is used for maintaining reactor level during hot shutdown or when the decay heat pumps are used for cold shutdow f. Cold Shutdown Cold shutdown can be accomplithed either by the decay heat removal system which can accept reactor coolant at a temperature of 470 F, or by feed and bleed using the overhead storage tank to feed water of less than 100 F to the reactor and the decay heat bypass valve to dump excess reactor coolant directly to'the main condense g. Alternative Shutdown Alternate shutdown is provided for the following areas:

. Control Room

. Electrical Equipment Room

. Crib House For fires in the Control Room or Electrical Equipment Room, shutdown is prov.ided for by manual control of the valves at the shutdown condenser (within the reactor building) and local direct readout A procedure for this has been developed and was demonstrated during this audi For fires affecting the crib house, all normal water sources (pumps)

are lost. The licensee maintains a group of gasoline engine driven pumps (four), three of which are manifolded together and are capable of extracting 900 gpm from the river and delivering this quantity to the high pressure water system in the turbine building at 90 ps h. Procedure Review The procedure for shutdown outside of the control room was revieved in detai It is Section 4.7 of Volume 1 of the operations ma ' s

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This volume contains all of the Integrated Plant Operation procedures, including normal operations and fire fighting instruction Section 4.7, entitled " Emergency Reactor Shutdown and Cooldown From Outside Control Room" is written for the general case of shutdown from outside of the control room for any reason, including fir The entire procedure can be accomplished by two licensed operators, leaving the other two operators of the minimum operating crew to join the fire brigad The procedure as written can be used to bring the reactor to cold shutdown using manual control of valves within the reactor building and local direct reading gauge i. Procedure Walkthrough The procedure for shutdown outside of the control room was walked through using only one operator in the reactor building and one remaining in the control ~ room to demonstrate comunications using two-way radios. It was demonstrated that the operator could be at the shutdown condenser and have the reactor in stable hot shutdown conditions within 10 minutes after discovery of the disabling fir Comunications were adequate from any point within the reactor building to the control room. All valves that had'to be manipulated were easily accessible and controllable by one perso Direct reading gauges required for control were easily accessible but in one case a gauge was not directly illuminated by the existing emergency lighting (the shutdown condenser level gauge). The inspectors recomended that the existing lighting pack lamps be re-positioned so as to light up the gauge directly. This is further discussed in Paragraph 2.p. of the report titled " Emergency Lighting."

In sumary, the walkthrough of the procedure demonstrated that the licensee could achieve stable hot shutdown, and proceed to cold shutdown outsioe of the control room, within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> as required by Appendix Associated Circuits Associated circuits were evaluated by the inspectors for common bus, spurious signal, and common enclosure concerns. Power, control, and instrumentation circuits were examined for potential problem Samples were selected based on the components which the licensee proposed to use for safe shutdown. The results of the evaluation

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are as follows:

(1) Comon Bus Concern The comon bus concern is found in either safety-related or nonsafety-related circuits where there is a comon power source with shutdown equipment, and the power source is not electrically protected from-the circuit of concer "

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The inspectors examined 2400V AC, 480V AC, 120V AC and 125V DC bus protective coordination and protection for specific

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instrumentation, control and power circuits, including the coordination of fuses and circuit breakers. Samples selected for the coordination review were as follows:

. Diesel Generator 1A Feeder Breaker - 452 EGA

. Emergency Core Spray 1A Breaker - 452 ESA

. Diesel Generator 1B Feeder Breaker - 452 EGB

. E.n rgency Core Spray 1B Breaker - 452 ESB

. Bus Tie Breaker - 452 TBA

. Bus Tie Breaker - 452 TBB

. Seal Injection Pump 1B Breaker - 452 ECCB

. Non Interruptible 120V AC The inspectors determined that the relay settings and fuse ratings, determined by Sargent & Lundy and Dairyland Power Cooperative in performing calibration and relay settings, were acceptable and that an on going relay coordination program is in plac (2) Spurious Signal Concern The spurious signal concern is made up of two items:

. False control and instrument indications can occur, such as those encountered during the Brown's Ferry Fire. These could be caused by fire initiated grounds, shorts or open circuit . Spurious operation of safety-related or nonsafety related components can occur that would adversely affect shutdown capability (e.g., RHR/RCS isolation valves).

The spurious signal concern is not a problem at this plan The licensee has demonstrated the ability to establish hot shutdown without electrical power being available to electrical equipmen (3) Common Enclosure Concern The common enclosure concern occurs when nonsafety-related cables are routed from an enclosure for one redundant train to another and a fire can thereby endanger both redundant train The licensee has specifically provided cable separation by rerouting cables for the following:

. One scram relay train

. One shutdown condenser control valve train

. One manual depressurization valve (AC)

. One manual depressurization valve (DC)

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These modifications provided the capability for alternative shutdown around the control room and the electrical equipment room. In the electrical penetration area, mineral insulated cable was installed in the circuitry between the containment and the control room. In addition, these cables were wrapped with one hour fire barrier material. Other cables outside of containment were considered to be lost as a result of fire and are therefore not needed for safe shutdown. The licensee demonstrated that safe shutdown is achievable by utilizing manual control or passive means, depending on the location of the fir This was detennined acceptable by the inspecto k. Current Transformer Secondaries The licensee had not completed the analysis for open current transformer secondaries as the result of a fire. The inspectors identified current transformer applications in the control circuits for the emergency diesel generators 1A and IB, which could be i damaged in a control room fire. No determination had been made by the licensee regarding the effects of this damage on the operability of the emergency diesels. Therefore, the licensee is requested to submit to Region III the the analysis for open

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current transformar secondaries as the result of a fire. This is considered an Open Item (409/85013-02(DRS)) pending Region III's

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review and acceptance of the licensee's submitta . High Low Pressure Interfaces There are no design high low pressure interfaces at this plan For personnel safety, the licensee provided a positive method for removing power to the solenoid of the RCS vent valves. The licensee installed switches in the mineral insulated control circuitry at the entry to containment for the AC solenoid vent valve No. 62-25-013 and DC solenoid vent valve No. 62-25-01 m. General Fire Instigated Signals The -125V DC control circuits for starting the emergency diesel generators 1A and 1B were not electrically isolated from the control room. A fire in the control room could cause a short which would cause the opening of the control circuit fuse protection. Local control at the emergency diesels would not be possible, even with fuse replacements, in the event of a sustained short circui Although the reactor can be shutdown from containment without the need for electrical power, availability of the diesel generators is

< the licensee's preferred method for achieving hot shutdown in the

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event of a loss of off site power. On August 30, 1985 in a

telephone conversation between the licensee and Region III, it was discussed that the reactor can be shutdown from containment without the need for electrical power; however, to maximize the availability of the emergency diesel generators, the licensee i

should look into the possibility of providing electrical isolation for their control circuits from the control roo ~7

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.. l In containment the licensee is depending on the effectiveness of the copper sheathing of mineral. insulated cable to prevent the occurrence of spurious actuation of components. Should a component spuriously actuate, the licensee proposes to remove electric power and manually operate the device. This was determined acceptable by the inspectors except as discussed in Spurious Signal Concern, Paragraph 2.j.(2) of the repor n. Crib House Fire Protection In a memorandum dated March 23, 1985 from W. Johnson, Division of Engineering, to G. Lainas, Division of Licensing, the enclosure entitled, " Chemical Engineering Branch / Fire Protection Section Supplemental Safety Evaluation Report Lacrosse Boiling Water Reactor Docket No. 50-409" indicated in Section 6.1, " Combined Water Supply," that both diesel fire pumps were vulnerable to damage from a single fire in the crib house. In the evaluation, the licensee's proposal to erect a partial height metal barrier between the fire pumps coupled with installation of an automatic sprinkler system (partial) and the existing smoke detectors provided NRR with reasonable assurance that at least one diesel pump would

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remain functional. Also, in the evaluation it was discussed that in the unlikely event that both pumps are damaged or if the capacity of one pump is insufficient to supply fire protection demands during a major fire, the licensee can supply this demand through the inter-connection of the nuclear plant's fire water main with the adjacent fossil plant water distribution syste A second backup water distribution capability is the Emergency Service Water Supply System (ESWSS) which can be made functional within one-half hou Based on the evaluation, NRR granted the licensee an exemption because the alternative fire protection configuration will achieve a level of fire protection equivalent to that provided by the technical requirements of Section II.A of Appendix R to 10 CFR Part 50 and Section C.2 of Appendix A to Branch Technical Position 9.5- The inspector observed in the crib house that there is a metal shield located between both fire pumps; however, the batteries for the diesel pump drivers are located adjacent to each other and could be easily damaged from a single fire. The batteries for each diesel pump driver should be separated by the metal shield to take full advantage of the protection offered by the metal shield. The inspector also observed that one branch line of the partial sprinkler system was provided with " heat collectors" as the sprinklers were located below recommended distances specified in NFPA 13, " Standard for the Installation of Sprinkler Systems," because an "I" beam and a 4 inch diameter pipe created an obstruction to the spray discharge pattern of the sprinkler system. The licensee has been requested to reevaluate the placement of the sprinkler heads in order to improve their sensitivit In addition, there are two smoke (ionization)

detectors located in the crib house which did not appear to provide adequate coverage for the crib house. The licensee has also been requested to evaluate the smoke detector placement utilizing

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NFPA 72E-1982, " Standard on Automatic Fire Detectors," to insure that a fire will be detected in its initial stages. These issues will be considered an Open Item (409/85013-03(DRS)) pending Region III's review and acceptance of the licensee's action o. Manual Fire Suppression Enclosure 2 of an NRC-NRR letter to the licensee dated November 24, 1980 identified Section III.D of Appendix R to 10 CFR Part 50 as being an open issue. -To meet the requirements of Section III.D, the licensee was requested to install additional hose stations and to increase the length of hose at stations up to a maximum length of 100 feet so that all areas of the plant are within reach of at least one effective hose stream in accordance with the requirements of NFPA 14. Further, the NRC-NRR letter indicated that for the licensee to meet the requirements of Section III.D of Appendix R to 10 CFR Part 50 and the recommendations of NFPA 14, " Standpipe and Hose Systems," the licensee should replace the existing unlined linen hoses with 11 inch 100% polyester, single jacketed, lined, FM or UL listed fire hoses, factory test rated at not less than 300 psig. In addition, all hose nozzles in use which were not UL or FM listed should be replaced with listed nozzle The hose stations located in safety-related areas were verified by the inspector to be provided with 11 inch, lined, single jacket, UL listed 75 foot hose lengths, rated for 300 psig with attached listed nozzles as required by NRR. The plant outside yard hose houses are equipped with li inch and 21 inch fire hose and hose house equipment which is maintained according to NRC requirement The inspector also indicated to the licensee that it appeared by visual observation that at least one effective hose stream could reach those safety-related areas of the plant toured with the interior fire hose attached to the station Based on the inspector's observations, the licensee meets Section 111.0 of Appendix R to 10 CFR Part 50 and is maintaining this fire equipment in accordance with NRC guideline p. Emergency Lighting Section III.J of Appendix R to 10 CFR Part 50 requires that emergency lighting units with at least an eight hour battery power supply shall be provided in all areas needed for operation of safe shutdown equipment and in access and egress routes to those area The inspectors examined the licensee's emergency lighting unit placement for adequacy of illumination levels so that operation of safe shutdown equipment and access to those areas can be accomplished. Also examined was the maintenance program for the required emergency lighting unit ..

(1) Lighting Unit Placement The inspectors questioned whether adequate illumination is available in the following plant areas:

(a) Along the path of the Containment Building stairway, 640' elevation (grade floor), to the 701' elevatio (b) Containment Air Lock area - One DC lighting unit was rewired-to an eight. hour battery; however, this bulb does not appear to give adequate illumination when both containment air lock doors are close (c) Upper platform of the shutdown condenser platform where an operator is required to read an instrument gag At the exit meeting of July 11, 1985, the licensee indicated that a walkdown would be performed along the required emergency lighted path to determine if adequate emergency lighting illumination levels are availabl (2) Emergency Lighting Units Preventive Maintenance Program The licensee has implemented two preventive maintenance checks on the eight hour emergency lighting units. including a monthly and an annual inspection. The monthly inspection includes a water level check of the battery units while the annual test includes an eight hour discharge test of the battery unit The inspector performed a review of these two maintenance procedures using the lighting unit manufacturer testing recommendation The following comments were generated as a result:

(a) Monthly Test This test procedure does not verify emergency DC power availability including the manufacturer's recommended ninety second test (i.e., depress momentary test switch, indicating lights off, sealed beam lamps on and aimed adequately, and voltmeter readings made).

(b) Annual Test The annual test should include the monthly test check information and results regarding the Eight Hour Lighting Unit Discharge Tes (3) Eight Hour Lighting Unit Discharge Test On July 10, 1985, at the request of the inspectors, an eight hour discharge test was performed on two lighting units to determine the operability of these. units in their installed condition. The two units tested had been previously tested

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(8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge test) on April 17 and June 7, 1985 by the plant maintenance staff. The inspector observed that the two lighting units lamps were still illuminated approximately eight hours after the start of the test and battery voltages were satisfactory; thus, the two lighting units were determined to have passed the discharge test requirements as specified by the lighting unit manufacture The inspector concerns in Section (1) and (2) are considered an Open Item (409/85013-04(DRS)) pending inspector followu Oil Collection System Section III.0 of Appendix R to 10 CFR Part 50 requires that the reactor coolant pumps (recirculation pump or forced circulation pump for boiling water reactors) be. equipped with an oil collection system if the containment is not inerted during normal operatio Because the LACBWR containment is not inerted during normal operation, an oil collection system is required.Section III.0 of Appendix R specifies that the oil collection system shall be so designed, engineered, and installed that failure will not lead to fire during normal operations or design basis accidents and that there is reasonable assurance that the system will withstand the Safe Shutdown Earthquake (SSE).

The licensee submitted an exemption request for the requirements of Section III.0 of Appendix R due to installed drip shield By letter dated March 1, 1982, NRR granted the licensee's exemption request based on removing the recirculation pump coupling oil (90 gallons per pump) and replacing the coupling oil with a non-flammable glycol-water solutio By letter dated March 23, 1982, the licensee informed the NRR Fire Protection Reviewer of changing from the use of a glycol-water (60%/40%) solution to Quintrolubric synthetic 822-TCF-150 fire resistant hydraulic fluid (combustible liquid having a flash point of 505 F). This was done for several reasons including (1) the recommended operating temperature of water base fluids is 130 F or less, while coupling fluid generally runs between 120 F to 140 F, (2) increased maintenance on glycol-water fluid is necessary to ensure the designed degree of fire resistance, (3) use of glycol-water in systems containing nonferrous metals and use of oil resistant paints should be avoided. The coupling components are made of cast aluminum and the sumps are internally and externally painted with an oil resisting epoxy paint. The licensee is presently utilizing Quintrolubric 822-TCF-150 hydraulic fluid in the Reactor Forced Circulation Pump Coupling 011 System. This is being evaluated by NRR (ltrMarch 23, 1982 from D. Rybarik (LACBWR) to Dennis Kubicki (NRC)). This is considered an Unresolved Item (409/85013-05(DRS))

pending NRR review and acceptance of Quintrolubric 822-TCF-150 hydraulic fluid in the Forced Circulation Pump Coupling Oil Syste No violations or deviations were identifie ..

3. License Condition Compliance According to License Condition 2.c(4), the licensee was required to complete various fire protection modifications identified in the NRC's Fire Protection Safety Evaluation dated July 27, 1979. The inspector examined a sample number of these plant fire protection modifications for compliance with the above stated License Condition. Fire protection features inspected by the inspector included the following: Two exterior hose houses were provided on the yard fire loop accessible to the "B" diesel generator area and one accessible to the northwest entrance to the turbine building. The inspector verified adequate. fire protection equipment was stored in the houses and is being maintained in these and two other exterior hose houses inspecte The inspector did make the following additional observations:

(1) one fire hydrant is installed outside the protected area (security fence) which provides a source of water for fire fighting purposes in safety-related areas of the plant. However, interior fire hose stations are the primary fire equipment to be used by the fire brigade for fighting fires; (2) if a fire in the crib house were to disable the High Pressure Service Water Diesel driven fire !

pumps, an alternative source of water is available by connecting the nuclear plant fire water system hydrants to the fossil plant fire water system hydrants using fire hose. During a plant tour the inspector observed that sufficient 21" hose (approximately 300'

needed to make the connection) was not stored in hose house number 4 (150' stored currently) to accomplish the connection. The inspector determined that adequate alternate protection was available including four Volkswagen gasoline engines (discussed in paragraph 2.g) and enough hose in other hose houses to make the connection to the fossil plan Manual firefighting equipment, including one smoke ejector rated for 5000 CFM, eight sets of firefighting protective clothing, six sprinkler stopper wedges, spare sprinkler heads, one sprinkler head wrench, spare hose gaskets, and two spare li" hose nozzles were stored in a centrally located location _ on elevation 654 feet in the washer / dryer area as required, The inspector verified that a six hour onsite self contained breathing apparatus air reserve is'available by way'of a cascade system located in warehouse number In addition, sufficient numbers of self contained breathing apparatus and spare bottles in a filled condition were observed by the inspector during tours of the plan An automatic wster fire suppression system is provided to protect

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- against a fjre at the outside transformers and an automatic halon fire supprescios system is installed in the electrical equipment-roo .

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e. The inspector observed no unsealed pipe penetrations in those safety-related areas of the turbine and reactor buildings that were toured. Cable penetration seal designs were not verified with supporting test dat f. The inspector observed that a hydrogen detector is installed in the electrical equipment and in the "1B" battery rooms, which contain the station batteries. Both hydrogen detectors alarm in the control room at a pre-detennined hydrogen concentration. In

' the inspector's review of the periodic maintenance program on the hydrogen detectors, it was noted that these detectors were due for a semi-annual surveillance test (previously completed in December 1984) during June 1985. These tests had not been completed at the time of the inspection visit although the 25 percent extension period as allowed by Technical Specifications had not expired. The hydrogen detectors are currently covered under the plant routine job tickler program which has a lower priority than a second program known as the " Preventive Maintenance Program." The inspector requested the licensee to switch the testing program for the hydrogen detectors. Licensee management agreed to consider the inspector's request. This is considered an Open Item (409/85013-06(DRS)) pending timeliness of the surveillance test completion, g. Fire resistive material had been sprayed on the exposed steel structure supports along the ceiling of the machine shop as require h. Three-hour rated fire door assemblies have been installed in the opening to the "A" diesel generator room and in the opening from the machine shop to the penetration room. The inspector also observed other approved fire door assemblies or electrically supervised fire doors in safety-related areas of the plan However, two fire door frame assemblies protecting the opening to the oil- storage room (adjacent to safety-related equipment) and one of the control room door assemblies which leads to the turbine floor was missing the Underwriters Laboratories label. In addition, a i inch piece of lexan plastic that covered the entire door and part of the frame assembly was installed on the control room doo The licensee provided the inspector with a copy of a Factory Mutual (FM) Engineering letter, dated August 16, 1982, regarding the li hour fire door assembly indicating that FM had no objection to the lexan plastic installation. The inspector advised the licensee that this letter would not be acceptable for the control room door assembly rated for 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and raised a question regarding the acceptance of the lexan application on the li hour fire _ door. At the exit meeting of July 11, 1985, acceptable methods of having the fire door frame assemblies listed were discussed. The fire door concerns discussed above are considered an Open Item (409/85013-07(DRS)) pending inspector followup on the licensee's resolution of these concerns, i

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.. Curbs were installed in "A" and "B" diesel generator. rooms and turbine oil reservoir area to contain the contents of oil if a leak or rupture were to occu Also, an opening at the floor level of the oil storage room is installed to drain a possible oil accumulation as require Section 5.7.4 of Safety Evaluation Report dated July 27, 1979, stated that ionization-type smoke detectors are located on the ceiling of the control room and in the ventilation air return ducts from the control room consoles. During a plant tour on July 8, 1985, the inspector observed that no area wide fire detectors were located on the ceiling of the control room. There is a detector located in the ventilation air return duct inside of the control console panel. Discussions between the NRR fire protection reviewer and Region III staff indicated that the NRR reviewer did expect an area wide fire dete'ction system installed in the control room to satisfy the plant fire protection program; however, the license condition (Amendment No. 17) related to the completion of facility modifications to improve the fire protection program did not include installation of an area wide fire detection system in the control room. The installation of an area wide fire detection system in the control room is necessary based on NRR acceptance of an area wide detection system. At the exit meeting of July 11, 1985, the licensee committed to installing an area wide fire detection system in the control room. This is considered an Open Item (409/85013-08(DRS))

pending installation of an area wide fire detection syste No violations or deviations were identifie . Incipient Fire Protection Equipment Section B.6.e of Appendix A of the licensee's response to the Branch Technical Position 9.5-1 stated, in part, " Testing and maintenance of the fire protection equipment is performed according to established schedules for the following: (a) portable extinguishers.... Portable extinguishers are inspected, tested, and maintained in accordance with FM recommendations contained in the FM Handbook of Industrial Loss Protection."

Section 4-6 of the FM Loss Prevention Data Sheets (formerly FM Handbook of Industrial Loss Protection) indicates that carbon dioxide extinguishers need to be hydrostatically tested every five year The " Inventory Sheet" of Fire Protection Program Implementing Procedure 6.5 has a column for the inspector to check when the last hydrostatic test was performed on the portable fire extinguisher The inspectors observed that the 100 pound C02 wheeled unit located on the main floor of the Turbine Building, 668' elevation, and two 5 pound CO2 extinguishing units located in the electrical equipment room (access way to control room benchboard consoles), 654' elevation were past due their scheduled periodic' hydrostatic retest. The 100 pound C02 wheeled

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unit was last tested in April 1978 and was due again during April 1983 while the two portable C02 units were last tested in February 1978 and were due again during February 198 This represents a violation (409/85013-09(DRS)) of Technical Specification 15.6.8.1.f concerning the implementation of the Fire Protection Progra No other violations or deviations were identifie . Fire Equipment Inventory Inspection The inspector reviewed Procedure No. FPP 6.7 titled, " Fire Equipment Location and Inventory and MSA Monthly Inspection" with the following comments: The handlights located at the fire brigade station were not being inventoried or functionally teste The smoke ejector located at the fire brigade station was not receiving a check to verify its operabilit These two comments are considered an Open Item (409/85013-10(DRS))

pending revision of this procedur No violations or deviations were identifie . Fire Protection Administrative Controls The inspector examined the licensee's fire protection administrative controls including the control of combustibles, fire protection audits, and inspections. These administrative controls were reviewed using the commitments and requirements in Amendment No. 17 to License No. OPR-45 including the Fire Protection Safety Evaluation Report issued July 27, 1979, and subsequent Safety Evaluation Reports, Lacrosse Nuclear Plant Fire Protection Review and Fire Hazards Analysis submitted February 14, 1977, and for reference purposes only the revised undated Fire Protection Review (not docketed), the Plant Technical Specifications for the fire protection systems, and supporting licensee transmittal The inspectors performed plant tours of the turbine and containment buildings including the control room, electric equipment room, crib house, electric penetration room, machine shop, oil storage room and the "A" and "B" diesel generator room During these plant tours, adequate housekeeping and control of combustibles was observed by the inspectors, although special mention was made at the exit meeting regarding the storage of materials in the electric equipment room. Section 3.1.22 of Amendment No. 17 to the licensee'.s operating license added a license condition which required the licensee to relocate record file cabinets stored in the electrical equipment room out of safety-related areas. The inspectors observed that the record file cabinets had been removed from the room and

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relocated to a nonsafety related office area; however, several cardboard boxes stored on the top of cabinets, a cardboard box on the floor containing filters, and gray cabine.s having drawers which contained miscellaneous amounts of combustible materials (i.e., plastic bags and paper bags) were observed. At the exit meeting of July 11, 1985, the inspector indicated that materials not essential for routine operation should be removed. This is :.unsidered an Open Item (409/85013-11(DRS))

pending licensee action and inspector followup on housekeeping and the control of combustible On July 8, 1985, the inspectors observed two cardboard boxes in the crib house lying on top of the screen wash pumps that contained light bulb fixtures along with other small amounts of ordinary combustibles. On July 11, 1985, these boxes were again observed by the inspectors on top of the screen wash pump As noted in Paragraph 2.n. of this report, the crib house fire protection features included a partial automatic sprinkler system and detection system, and a radiant heat shield separating the two High Pressure Core Spray diesel driven fire pumps. The area of the crib house where the cardboard boxes were located did not appear to be adequately covered by fire detectors, nor was sprinkler protection provided overhead. In the inspector review of Administrative Control Procedure ACP-02.5, dated March 28, 1984, no specific administrative limit was found regarding transient combustibles in safety-related areas. This lack of an administrative limit on transient combustibles plus, in some cases, such as the crib house, partial fire protection features, may lead to inadequate protection against a fire if one were to occur. While alternative methods of supplying water for safe shutdown and fire protection are available, the crib house fire protection features should be evaluated on their own meri No violations or deviations were identifie . Annual Fire Pump Test In the crib house there are two diesel driven vertical shaft pumps that are utilized for alternative core spray and fire protection water spray systems. The pumps (HPSW 1A and HPSW 1B) are tested for core spray functions according to Data Sheet 17.5.2 entitled " Refueling Shutdown Test of Alternative Core Spray System" (RSTACSS) which requires that the pumps deliver a minimum of 900 gpm at a pump discharge of at least 320 feet (130 psig) (Technical Specification 5.2.18.1.1.d.2).

This test does not incorporate the various flows and pressures that would be expected of the pumps under load from possible fire fighting

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operations. To insure that the pumps will perform as designed to supply water to the automatic and manual water fire suppression systems, the licensee has been requested to conduct an annual fire pump test during refueling outages. The annual fire pump test will confirm that the pump, driver, suction and the power supply will operate properly or will indicate potential problems which should be corrected before adversely affecting any fire fighting operations. The annual fire pump test should

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incorporate testing the pumps at: (1) shutoff, (2) rated pressure and flow, and (3) overload. Resolution of this issue is considered an Open Item (409/85013-12(DRS)).

No violations or deviations were identified.

, ~ Updating Fire Hazard Analysis and Safeguards Report There are two diesel driven fire pumps (HPSW IA and HPSW 18) that he e been upgraded from 5 stage vertical shaft pumps to 6 stage vertical shaft pumps. The licensee has been requested to update the Fire Hazard Analysis (FHA) and the Safeguards Report (SR) to include the new ratings ,

(at 750 gallons per minute) of.the fire pumps. This'is considered am Open Item (409/85013-13(DRS)).

No violations or deviations were identifie . Operating Surveillance Procedures The inspector reviewed a sample of the licensee's technical specification surveillance procedures and verified that the minimum provisions of the Technical Specifications were-me The sample of surveillance procedures reviewed is as follows:

Number Title 7. Monthly Diesel Fire Pump Test (1A &'IB)

7. Monthly Fire Suppression System and Hose Station Inspection 7. Semi-Annual Flush of the Fire Suppression Water System 7. Annual Fire Suppression and Sprinkler System Test 7.4.10 18 Month HPSW/ACS Diesel Inspection Procedure 8. B Diesel Room C02 Quantity

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1A HPSW Diesel Weekly Starting Battery Report

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1B HPSW Diesel Weekly Starting Battery Report No violations or deviations were identified.

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10. Fire Brigade Composition Technical Specification 6.2.2.f requires that'a fire brigade of at least five members be onsite at all times. The licensee meets this requirement by designating two on-shift licensed operators, a health physics technician, and two security personnel as fire brigade members. This composition is consistent with the

, requirements of 10 CFR 50 Appendix R and Appendix A to Branch i Technical Position 9.5-1.

. During discussions with the licensee's staff it was identifled

, that the Shift. Supervisor is normally designated as the fire brigade leader but is given the option of delegating that responsibility to

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another licensed operator. This practice is discouraged by Appendix A to Branch Technical Position 9.5-1 and prohibited by 10 CFR 50 Appendix R, Section III.H. The licensee's fire brigade was previously reviewed and accepted against Appendix A to Branch Technical Position 9.5-1 and, as such, is not subject to the requirements of 10 CFR 50 Appendix R, Section III.H. Consequently, the licensee's practice is not in violation of regulato v requirements; however, the licensee is encouraged to rc.onsider the use of the Shift Supervisor as the fire brigade leade b. Trainino Fire brigade training requirements are specified in procedure FPP-02.2, " Fire Brigade Training." This procedure requires biannual training of fire brigade members in the following areas:

(1) Identification of fire hazards in the plant (2) Identification and location of fire fighting equipment within the plant (3) Proper use of available fire fighting equipment (4) Review of Fire Fighting Plan (5) Proper use of communication, lighting, ventilation, and emergency breathing equipment (6) Direction of fire fighting activities (7) Toxic characteristics of combustion products (8) Proper methods of fighting fires in enclosed spaces (9) Detailed review of fire fighting procedures (10) Review of latest plant modification which have an impact on fire protection measures and subsequent changes in the Fire Fighting Plan Annual practice sessions are held during which actual fires are extinguished and emergency breathing equipment is utilized. Makeup training for missed sessions is required within 90 day Quarterly drills are required for each brigade with at least one drill per year on a backshift. Drill evaluation sheets must be completed identifying brigade effectiveness and knowledge of fire fighting equipment. Additionally, FPP-02.2 requires quarterly meetings to review fire protection program changes. Participation in drills and attendance at critiques are taken credit for in satisfying this requiremen This program conforms to the requirements contained in 10 CFR 50 Appendix R and Appendix A to Branch Technical Position 9.5-1; however, the following weaknesses were noted in program implementation based on discussions with the licensee's staff and review of training records:

(1) Fonnal criteria for evaluating quarterly drill performance have not been establishe ..

(2) Lesson plans have not been developed for the topics required to be covered every two year (3) While training session attendance records are kept, the records do not consistently identify the subject material covered. Consequently, it is not possible to verify that all fire brigade members have received all required trainin (4) The licensee has not established a policy concerning fire brigade qualification requirements for personnel standing operating watches for license maintenance purposes onl With respect to item 3, the inspector noted that most of the topics for which formal training is required are covered during an annual training session provided by a contractor. Much of the remaining material is covered by routine practices such as operations performance of surveillance testing on fire fighting equipmen Correction of these weaknesses will be tracked as an Open Item (409/85013-14(DRS)).

No violations or deviations were. identifie . Electrical Equipment Room (Fire Area No. 9)

Section 3.2.9.1 of the Fire Hazard Analysis of the Lacrosse Boiling Water Reactor, titled " Fire Area No. 9," states, "This fire area is of noncombustible construction with concrete floors on exposed stee The center control room console extends between the two floors making this all one fire area.' The area is separated from the Turbine Building by 12-inch reinforced concrete walls and approved, 3-hour, Class'A fire doors. It is separated from the Office Building by a minimum of 6-inch masonry walls and 1 -hour, Class B fire door Air conditioning for the two rooms is provided by an air handler in the electrical equiprent room. Fresh air is brought in from the outside and conditioned before circulating to both floors."

There is a halon suppression system installed for the Electrical Equipment Room in addition to 1 inch fire hose with spray nozzles which is available to both the Control Room and Electrical Equipment Roo Section 3.2.9.4 states, " combustibles in the electrical equipment room include about 1500 lbs. of cable insulation that is coated with Flamastic 71A. This cable meets former ICEPA Standards S-19-81 and-5-61-402 for flame spread and was installed before IEEE 383 became effective. This represents about 19.5 x 108 BTU or 18,000 BTU per square foot of the room. The electrical equipment room also houses two separate banks of batteries."

Section 4.4.5 of the " Plant Shutdown Analysis" titled, " Fire Area 9, Electrical Equipment Room (and Control Room)," states, "It has been

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assumed that a major fire in the Electrical Equipment Room will either disable major reactor control circuits or preclude occupation of the Control Room. Consequently, boron injection may not be available for reactor shutdown and supplementary cooling systems such as Decay Heat and Purification may not be operational eithe However, reactor shutdown is assured by the ability to insert control rods either automatically if fire causes loss of the 120V non-interruptible bus or manually from RBMCCIA in the Containment Building. Reactor cooling is assured by the continued availability of two full-capacity systems (shutdown condenser and HPCS System) as well as supplementary systems which may require manual operation of valves and pumps (e.g., ESWSS System).

While control room indication of reactor parameters may be unavailable, reactor pressure gauges and the reactor water level gauge and sight glass are available inside containment to verify reactor shutdown and to monitor shutdcwn cooling. Portable radiation instruments can also be used to verify reactor shutdow It is the inspector's concern that hydrogen is evolved when batteries are recharged and sufficient quantities may accumulate and be ignited by nearby electrical equipment should the ventilation system become inoperable or shutdown for an extended period of time. The Electrical Equipment Room (Fire Area No. 9) is an area where storage batteries are recharged (where hydrogen is evolved) and is considered a Class I, Division II area based on the 1984 National Fire Codes, Volume 3, National Electrical Code, Chapter 5, "Special Occupancies,"

Section 500-4.(b) Class I, Division 2. A Class I, Division 2 location is a location where ignitable concentrations of gasses or vapors are normally prevented by' positive mechanical ventilation and which might become hazardous through failure or abnormal operation of the ventilating equipmen In the Fire Hazard Analysis "LACBWR Response - NUREG 75/987,"

Section 9.5.1, " Fire Protection" Overall Requirements of Nuclear Plant fire Protection" Section B. it states:

"NRC Position Plant layouts should be arranged to:

(1) Isolate safety-related systems from unacceptable fire hazards and (2) Separate reoundant safety-related systems from each other so that both are not subject to damage from a single fire hazard (or protect the safety system from the fire).

DPC Response With a plant layout constructed prior to the issuance of NRC's branch technical position, the emphasis must be on prevention of an unacceptable fire hazard and protection of the safety systems from a potential fire."

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The licensee has installed a hydrogen detector in the room that alarms in the Control Room to allow the licensee to take action to prevent an unacceptable fire hazard; however, . isolation and separation are not -,

provided. This issue is to be investigated in future inspection No violations or deviations were identifie q 12. Open Items 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 of both. Open items disclosed ~during the inspection are discussed in Paragraphs 2.d, 2.k, 2.n, 2.p, 2.q, .h 3.j, 4, 5, 6, 7, 8, and 1 ,

13. Unresolved Items ,

i* t Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance, or deviations. An unresolved item disclosed during the hspection is discussed in Paragraph . Exit Interview The inspectors met with the licensee representattves at the conclusion of the inspection on July 11, 1985 and summarized the scope and findings of the inspection. The licensee acknowledged the statements made by the ,

inspector. The inspector also discussed the likely informational content of the inspection report with regard to documents reviewed by the y inspector during the inspection. The licensee did not identify any such documents as proprietary. On August 20, and August 30, 1985, in telephone conversations between J. Parkyn, LACBWR, and J. Holmes; NRC, additional concerns regarding the electrical equipment room and the poss-ibility of providing electrical isolation for the emergency diesel generator circuits from the control room were discusse ' ,

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