ML17195B022
| ML17195B022 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 11/13/1985 |
| From: | Guldemond W, Holmes J, Ramsey C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17195B021 | List: |
| References | |
| 50-237-85-33, 50-249-85-29, NUDOCS 8511190084 | |
| Download: ML17195B022 (17) | |
See also: IR 05000237/1985033
Text
..
. U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Reports No. 50-237/85033(DRS); 50-249/85029(DRS)
Docket Nos. 50-237; 50-249
Licensee:
Commonwealth Edison Company
P. 0. Box 767
Chicago, IL 60690
Facility Name:
Dresden Nuclear Power Station, Units 2 and* 3
Inspection At:
Morris, IL
Inspection Conducted:
September 30 through October 21, 1985
C\\J)J ~
Inspectors:
~Holmes
Approved By:
W. G.
ul
mond, Chief
Operational Programs Section
Inspection Summary
Inspection on Settember 30 through October 21, 1985 (Reports
No. 50-237/85033 DRS); 50-249/85 29(DRS))
II- f 3-85°
Date
ti - 1*-B~
Date
Areas Inspected:
Routine, unannounced safety inspection conducted to verify
the adequacy of the facility's fire.protection program implementation and to
determine the status of LERs and previous open items.
The inspection involved
71 inspector-hours by two NRC inspectors including 2 inspector-hours onsite
during off-shifts and 11 inspector-hours conducting in-office review at the
Region III off,ice.
Results:
Of the 6 areas inspected, no violations or deviations were identified
in four areas.
Two violations were identified in the remaining two areas
(failure to adhere to program staffing requirements - Paragraph 3; failure to
comply with a license condition to install an automatic fire detection system
in the Reactor Building refueling floor ar~a - Paragraph 7a).
9511190084 e§!ll.~7
ADOCK O~oR
-<-
0
1.
DETAILS-
D. Adam, Compliance Administrator
- J. Brunner, Assistant Superintendent, Technical Services
T. Ciesla, Assistant Superintendent, Operations
- M. Dillon, Fire Marshall
- R. Flissner, Service Superintendent
- T. Hausheer, Nuclear Services, Technical
- P. Lau, QA Supervisor
- J. McDonald, Station Nuclear Engineering
- B. Rybak, Station Nuclear Engineering
- D. Scott, Station Manager
- R. Whalen, Technical Staff
J. Wujciga, Production Superintendent
US NRC
E. Hare, Resident Inspector
- L. McGregor, Senior Resident Inspector
S. Stasek, Resident Inspector
- Denotes those in attendance at the exit meeting of October 4, 1985.
2.
Licensee Actions on Previous Inspection Findings
a.
(Open) LER (237/85029) and Violation (237/85028-01):
Auxiliary
electric equipment room halon system declared inoperable due to
ventilation dampers failing to close.
Fire watch was not established
per Technical Specification No. 3.12.H.2.
Region III 1s followup of this event is documented in Inspection
Report No. 50-237/85028(DRS).
As a result of this followup violation
No. 237/85028-01 was issued.
No response to this violation was
required because the licensee 1s interim and long term corrective
actions were determined satisfactory.
The interim corrective actions
were implemented.prior to or during the followup inspection.
The
proposed long term corrective actions have not been implemented.
Therefore, this event report remains open.
b.
(Closed) LER (249/85014):
Wet pipe sprinkler system in Unit 3
turbine trackway had to be rerouted to allow for overhead clearance
for new turbine rotors.
The sprinkler system was out of service
5 1/2 hours beyond the 14 day limit permitted by Technical
Specification 3.12.C.3 .
2
c.
The event report is closed based on the licensee's corrective
actions* taken. which included restoration of the system to service
and~functiona*l testing prior to declaring the system operable .
. '((:fii:&~df LER (237/85010):
Fire door for the Unit 2 125V DC battery
room found open.
A fire watch was not established within one hour
per Technical Specification 3.12.F.2.
This event report is closed based on the licensee's corrective
actions taken which included immediate closure of the fire door and
training/instruction of plant operators on the requirements to keep
fire doors closed at all times when not in use.
d.
(Open) LER (237/84-20):
Two of seven root valves that were installed
on fire hose stations were found to be in the closed position
rendering the fire hose stations inoperable.
e.
Although the licensee's corrective actions for this event included
prompt opening of the closed root valves, the inspectors determined
that the licensee's program for administratively controlling valves
that are not electrically supervised using wire seals to secure these
valves _in the open position and performing monthly inspections to
~
verify valve positions does not appear to be .working.
During the
-~
inspection the inspectors observed several non-electrically supervised
valves in the fire protection system with missing or damaged wire
seals .
To correct this problem, the licensee stated that the program for
administratively controlling these valves is being upgraded to
include locking these valves (chain and lock) in the open position
in addition to monthly inspections to verify each valve position in
accordance with NFPA Standard 26.
This event report remains open
pending Region III verification of the licensee's upgraded corrective
actions.
(Open) LER (237/84-17; 237/84-05):
Failure to establish continuous
or'-hourly fire watch patrols due to inoperability of all or portions
of fire detection and sprinkler alarm systems in the control room.
During these events and at the present time, the fire detection and
sprinkler alarm system printer indications are interlocked (dependent)
into the plant security system computer.
Indication of fire detection
and sprinkler alarms in the control room was lost in two events either
because of a loss of power to the plant security system computer or
because of modifications being made to upgrade the plant security
system computer.
Apparently, any failure of the plant security
system computer can cause the loss of all or portions of fire
detection and sprinkler alarm annunciation in the control room.
This installation does not comply with the licensee's commitment to
NFPA 720 as stated in the licensee's April 1977 response (point-by-
point comparison) to Appendix A to NRC Branch Technical Position
3
f.
(BTP) APCSB 9.5-1.
The licensee
1s scheduled plant modification
No .. ;~12-2/3-84-109 identifies corrective action for this problem as
the-:A*nstallation of independent circuits for fire detection and
spr'.fhkler system alarms which alarm and annunciate in the control
room'~n accordance with NFPA 720.
This modification is scheduled to
be completed in December 1985.
These LERs will remain open pending
Region III verification of the licensee
1s corrective actions.
(Closed) LER (237/84-11):
Fire wall penetrations to.Unit 2/3
diesel generator rooms were not sealed.
This event report is closed based on the licensee 1 s corrective
actions taken, which include establishment of a fire watch within
one hour per Technical Specification No. 3.12.F.2 and sealing the
penetrations per drawing No. 12E-6058.
g.
(Closed) LER (237/84-08):
NRC inspection of the licensee 1s
compliance with fire protection Technical Specification surveillance
requirements identified that a cardox system master valve was not
being tested in the automatic mode.
The master valve test procedure
was written to test the valve in the manual mode.
This event report is closed based on the licensee 1s corrective
actions taken which included prompt removal of the master valve
from service, revision of the surveillance test procedure, and
satisfactory testing o~ the valve in the automatic mode.
h.
(Closed) LER (249/83-34/03L):
Unit 3 trackway sprinkler system out
of service due to damage by mobile crane boom.
This event is closed based on the licensee 1 s corrective actions
taken, which included making the necessary system repairs, prompt
restoration of the system to service and instructions to plant
personnel regarding the movement of mobile cranes and the fragility
of systems and components in their path.
i.
(C)-0sed) LER (249/83-17/03L):
HPCI deluge system solenoid valve
taken out of service because the valve would not reset.
j.
This event report is closed based on the licensee 1 s corrective
actions taken, which included prompt removal of the deluge system
froni-service, making the necessary repairs to the solenoid valve and
restoration of the system to service.
(Closed) LER (237/81-15/03L):
Unit 2/3 diesel generator room C02
system heat detector surveillances not performed per Technical
Specification 4.12.A.1.
This event report is closed based on the licensee 1s corrective
actions taken, which included instruction to plant personnel to
perform the required heat detector surveillances and satisfactory
performance of the surveillance .
4
k.
(Closed) Violations (237/81-09-01; 249/81-06-01):
Four penetration
seals identified as being defective were inoperable for an excessive
per_t~rj;.* of time.
Neither prompt nor timely corrective action was taken.
This~ item is closed based on the licensee's June 29, 1981 response
to Region III which discussed the licensee's corrective actions
taken to avoid future violations in this area.
The inspector's
review of Procedure No. DFPP-4175-2, Revision 4, indicated that
appropriate instructions are provided to plant personnel which
refer to detail drawings for proper installation of penetration
fire seals.
1.
(Open) Violations (237/81-09-03; 249/81-06-03):
(a) Fifty percent
of fire extinguishers sampled did not have 1981 monthly inspection
tags attached; (b) 5 year hydrostatic test for portable C02
extinguisher cylinders were overdue; and (c) numerous compressed
gas cylinders were improperly stored.
m.
The licensee's corrective actions identified in their June 29, 1981
response to items (a) and (b) of this violation were ineffective.
Subsequent QA audits and surveillance by the licensee's onsite QA
department have revealed that these deficiencies are continuing.
For example, deficiencies identified in QA surveillance No. QAS
j
12-85-236 for the period September 23 through 29, 1985 include the
following:
wrong date on extinguisher tags; extinguishers past due*
for 5 year hydro testing; no service date on extinguisher tags; no
seal on extinguisher plill pin; partially discharged extinguisher.
During plant tours by the inspectors, identical deficiencies were
observed.
In one instance, a C02 portable extinguisher hose was
damaged to the extent that the webbing in the hose was exposed.
A hole existed in the webbing that may have allowed the extinguishing
agent to escape through the hose prior to reaching the C02 discharge
nozzle.
This extinguisher was located on fire cart No. 2.
In
addition, the inspectors observed that wheeled dry chemical
extinguishing units*Nos. PK 21 and PK 22 had tags which indicated
th~t surveillances were missed the months of May and September 1985.
The continuing existence of this type of deficiency is indicative of
a lack of management attention in this area.
Management attention
and staffing is the subject of a violation documented in paragraph
3 of this report.
Your response to that violation should address
your corrective actions for failing to properly maintain fire
extinguishers.
These items will remain open pending the further
review of the licensee's corrective actions by Region III.
Item (c) of this violation is closed based on the licensee's
corrective action taken which included the installation of metal
storage racks for compressed gas cylinders, securing the cylinders
with metal chain~ and revision of Procedure No. OAP 3-11.
I
(Open) Unresolved Item (237/81-09-06; 249/81-06-06):
Fire brigade
drills and training do not appear to meet the intent of NRC
requirements.
5
"Section 6.0 of the original fire protection SER, dated March 1978,
- recommended. that the licensee's administrative controls follow the
.... gµ.(~e)!Jnes set forth in the NRC Guidance Document entitled 11 Nuclear
- .* Plai\\t;.Fire Protection Functional Responsibilities, Administrative
Controls* and Quality Assurance.
11
A supplement to the original SER
was issued December 2, 1980.
Section 3.1 of this supplemental SER
closes out the issue of administrative controls with the NRC staff's
acceptance of the licensee's discussion of administrative controls
provided in letters dated January 24, February 24, March 20 and
July 27, 1978, January 31, and April 30, 1979.
Therefore, Section
III.1.3.b of Appendix R is not applicable to administrative controls
for fire protection at Dresden.
Based on the licensee's submittals discussed above, the NRC staff
concluded that the licensee's administrative controls for fire
protection met NRC guidelines and, the applicable regulatory
requirement for fire protection administrative controls at Dresden
is the Commission 1s guidance issued on the implementation of General
Design Criterion 3 of Appendix A to 10 CFR Part 50 for existing
power plants.
Section 2.0 and 3.0 of Attachment No. 2 to NRC Guidance Document
~
..
11 Nuclear Plant Fire Protection Functional Responsibilities,
Administrative Controls and Quality Assurance
11 requires practice
sessions be held for fire brigade members to provide each brigade
member wi.th experience in actual fire extinguishment and the use of
emergency breathing apparatus under strenuous conditions.
Fire
brigade dri 11 s are required to be performed so that th*e fire brigade
can practice as a team.
The drills are to be performed at regular
intervals but not to exceed three months for each fire brigade.
The
drills are required to be critiqued to assess each brigade member's
knowledge of his role in fire fighting strategy.
The licensee is not meeting these requirements for the following
reasons:
(1)
By attempting to meet the requirements contained in
Section III.1.3.b of Appendix R to 10 CFR 50, the licensee
has been conducting one fire drill per month with the intent
of getting all designated fire brigade members involved in
at least two drills per year.
(2)-* Practice sessions that provide each brigade member with actual
fire extinguishment experience and the use of emergency
breathing apparatus under strenuous conditions (full fire
fighting gear) have not been conducted due to a breakdown in
contractual arrangements with an independent firm.
(3) Fire brigade drills have not been critiqued at three year
intervals by qualified individuals independent of the
licensee's staff .
6
3.
To resolve this concern, the licensee is requested to make available
a detailed assessment of fire brigade drills, practice sessions and
thrf!,~_year. audits of fire brigade drills by qualified individuals
_.- -. indeRendent of the licensee* s staff. This assessment should
- establi.sh whether the licensee is in compliance with commitments
made to the NRC which resulted in the NRC staff conclusions that
the licensee 1s administrative controls for fire protection were
acceptable.
This item remains open pending region review of the licensee*s
assessment.
n.
(Open) Unresolved Item (237/81-09-07; 249/81-06-07):
Specific
pre-fire fighting plans or strategies for all safety-related areas
and areas presenting a hazard to safety-related equipment were not
developed and implemented.
As discussed in item 237/81-09-06; 249/81-06-06 above, the
requirements of 10 CFR 50, Appendix R (Sections III.K.11 and 12)
are not applicable in this case.
The applicable requirements are
contained in Attachment No. 5 of NRC Guidance Document
11Nuclear
Plant Fire Protection Functional Responsibilities, Administrative
Controls and Quality Assurance.
11
During the inspection, the licensee provided the inspectors with
a copy of pre-fire plans that contained specific fire fighting
strategies for fighting fires in all safety-related areas and
areas that present a hazard to safety-related equipment.
The
pre-fire plans appear to provide adequate fire fighting procedures
and instructions.
However, these plans have not been implemented.
According to the licensee, the plans will be implemented and
incorporated into fire*brigade training lesson plans by the end
of the first quarter of 1986.
This item will remain open pending
said implementation.
o.
(Open) Unresolved Item (237/81-09-08; 249/81-06-08):
Fire brigade
practice sessions have not been conducted in accordance with
commitments made to the NRC.
A hands-on practice session was held
in 1979 with full brigade attendance, but no practice session was
held in 1980.
This item will remain open pending Region III review of the
licensee's response to Item b of Unresolved Item No. 237/81-09-06;
249/81-06-06 as discussed in this report.
Fire Protection Program Organization and Personnel Staffing
.;,
f;
c
10 CFR 50.48 requires that each operating nuclear power plant have a fire
protection plan that satisfies Criterion 3 of Appendix A to 10 CFR 50.
Except for the requirements of Section III.G, III.J, and III.O of
Appendix R to 10 CFR 50, the approved fire protection plan that satisfies
Criterion 3 of Appendix A to 10 CFR 50 is discussed in the original fire
protecti'on SER. dated March 1978, a fire protection SER Supplement, dated
December 2, 1980, and the licensee 1s Fire Hazard Analysis submittals entitled
7
11 InformaU.on .Relevant to Fire Protection. Systems and Programs" dated
Octobe~ l976,.January 1977, and April 1977.
Furthermore, the licensee
committe:d\\'.t,o~ follow certain NRC Supplemental Gui dance Documents as
discusse,~;';{6. letters to the NRC, dated January 24, February 24, March 20
and July*:?;2T, 1978; January 31 and April 30, 1979.
The requirements for overall responsibility for the Fire Protection
Program are discussed in Sections IV.A and 3.1.A.1 of Parts 1 and 3 of
the licensee
1s Fire Hazard Analysis submittal, dated October 1, 1976
and April 1977.
The NRC
1s position, as restated stated in Section 3.1.A.l
of this document establishes guidance on implementation of basic criteria
for fire protection program organization and personnel staffing.
In response to the NRC
1s position discussed in Section A.l of Appendix A
to NRC Branch Technical Position APCSB 9.5-1 concerning the qualification
requirements for the Fire Protection Engineer who will assist in various
aspects of fire protection program development for the operating plant,
the licensee states
11comply
11 in Section 3.1.A.l of the Fire Hazard
Analysis submittal.
The licensee further states, in part,
11 CEC0 has a
Fire Protection Coordinator who reports to the Supervisor of Safety ..
Responsibilities of the Fire Protection Coordinator are:
coordination
of activities; procurement of equipment, resolve questions on standards f
and technical issues; make recommendations for improvements; coordinate,~
plan, and conduct inspections (make inspections of Dresden, Units 2 and ~~
once a month); ensure that adequate fire fighting equipment is provided -
and that such equipment is maintained in good operating condition,
coordinate with offsite fire department; conduct normal and preoperational
testing; provide forms and instructions for reporting fires; issue
publications outlining employee policy and procedures in fire protection;
assist and supervise training of personnel; assist and advise departments
concerned with established rules and standards; coordinate with the staff
all matters of mutual concern and make final recommendations for specific
actions to be taken on fire protection issues.
11
The inspectors identified the following examples of the licensee
1s
failure:to consistently and effectively comply with the staffing
requirements for fire protection program implementation:
a.
Fire Protection Engineer
A qualified Fire Protection Engineer was not involved in the
deve.1 opment of certain aspects of the fire protection program
for the operating pl ant as required by Sect ion 3. 1. A. 1 of the
licensee 1s Fire Hazard Analysis submittal.
The qualifications for
this individual were not stated in any document.
The resume of the
individual performing the original Fire Hazard Analysis is contained
in Attachment 2A of the Fire Hazard Analysis submittal, but this
individual is no longer employed by the licensee.
According to the licensee, there was a contract with M&M Protection
Consultants which included services that would satisfy some of the
responsibilities of the Fire Protection Engineer, but this contract
expired in December 1984.
8
Although the licensee has employed another qualified Fire Protection
Cons*4aant- firm to do some specific fire protection work relative to
upgJtc;1dHJg the fire protection program, this firm was not retained to*
ful.fj~lyall of the responsibilities of the Fire Protection Engineer.
b.
Fire Protection Coordinator
The Fire Protection Coordinator was not performing all the duties
at the site that are delineated in Section 3.1.A.l of the licensee's
Fire Hazard Analysis. submittal.
According to the licensee's staff,
the individual that was originally assigned these duties was trans-
ferred to Corporate Quality Assurance some time ago.
Once vacated,
this position was not filled.
The duties and responsibilities of
the position were delegated to the Fire Marshal and other individuals
within the CECo organization.
Through Amendment No. 86 to Facility Operating License No. DPR-19
(Unit 2) and Amendment No. 79 to Facility Operating License No. DPR-25
(Unit 3), the NRC accepted a proposed licensee staffing change.
Figure 6.1-1 (Corporate and Station Organization Chart) shows a Fire
Protection Inspector reporting to the Corporate Director of Quality
Assurance Operations.
The inspectors requested, but the licensee di~
not provide the inspectors with documentatio~ to verify that the NR~
was aware that the same individual who was the site Fire Protection-~
Coor.dinator was filling the position entitled "Fire Protection
Inspector" for Corporate Quality Assurance.
The licensee's failure to adhere to the staffing requirements
discussed above resulted in programmatic breakdowns that have
decreased the level of fire protection that was intended to
satisfy Criterion 3 of Appendix A to 10 CFR 50.
For example:
(1) A fire detection system was not installed on the refueling
floor as required by Amendment No. 33 to Facility Operating
License No. DPR-25.
(This is discussed in Paragraph 7.a of
, the report. )
(2) Installed fire protection hardware and equipment was not
being properly maintained.
(This is discussed in Paragraphs
2.d, 2.e, 4, 5, and 7 of the report.)
(3) Technical specification surveillance procedures did not
incorporate appropriate testing of quality affecting parameters *
in accordance with design and governing code requirements.
(This is discussed in Paragraph 4 of the report.)
(4) Administrative controls did not adequately control fire
protection features.
(This is discussed in Paragraph 5 of
the report.)
(5)
Many deficiencies that were identified in LERs, NRC inspections,
QA audits, and QA surveillances did not receive prompt or effec-
tive.corrective action.
(This is discussed in Paragraph 2 and 6
of the report.)
9
(6)
W~C!knesses in the scheduling of fire drills were identified.
~L(This is discussed in Paragraphs 2.m, and 2.o of this report).
Fafl\\ife- to; comply with the staffing requirements for development and
implerilentatiori of the fire protection program is considered a
violation of 10 CFR 50.48 and Criterion 3 of Appendix A to 10 CFR 50
(237/85033-01; 249/85029-0l(DRS)).
The Station Fire Marshal
1s qualifications include 58 junior college
credits in fire science; an associates degree in electronics
engineering and 15 years experience as a volunteer firefighter.
He
has held the position of station fire marshal for seven years.
At
the present time, the fire marshal is assigned the following
responsibilities:
a.
Coordinate and assist in fire systems periodic testing.
b.
Plan, coordinate, conduct, and critique fire drills.
c.
Fire Brigade classroom training.
d.
Review, revise, and write new administrative procedures.
e.
Review, revise and write new surveillance procedures.
Make
work requests to repair deficiencies, verify surveillances
are completed as required and maintain files on completed
surveillances.
,
f.
Review plant modifications, assist in training, testing, and
development of procedures.
g.
Maintain fire equipment, verify availability of spare parts and
procurement of parts.
h.
Participates in insurance inspections, Technical Specification
Reviews, QA, INPO, and NRC audits.
i.
Assure Technical Specification compliance.
j.
Review work requests.
k.
Verify fire watch and insurance notification.
1.
Coordinate activities with the offsite fire department.
m.
Make reports on deviations and fire damage experiences.
n.
Perform plant cleanliness inspections.
o.
Correspond with other agencies on fire protection issues.
p .
Assure that the fire protection program meets NRC and other
requirements.
10
q *. Explain fire protection* requirements to the licensee's staff
when required.
Accorcfing to the licensee's staff and Station Nuclear Engineering
Depa:rtment (SNED) procedure number PE Q.44, a qualified corporate
fire protection engineer reviews new plant modifications prior to
implementation by the Architect-Engineering firm. *This appears to
be the extent of the corporate fire protection engineer's involvement.
The qualifications of the Station Fire Marshal do not appear to be
commensurate with the list of responsibilities assigned to that
position. This lengthy list of responsibilities constitute a workload that
may not be achievable by a single individual, regardless of the
individual's qualification and experience.
To resolve this concern, the licensee is requested to provide at
the site, a written evaluation (complete work study) of the responsi-
bilities assigned to the station fire marshal. This evaluation
should make a determination of the fire marshal's ability to
effectively achieve each delegated responsibility based on his
qualifications and time constraints.
This is considered an Unresolved Item (237/85033-02; 249/85029-02{DRS))
pending Region Ill's review of this evaluation.
..
4.
Technical Specification Surveillance Review
Technical Specification 6.2.A.11 requires that detailed written procedures
be developed, approved and adhered to for implementation of the Fire
Protection Program.
The inspector's review of the licensee's surveillance
procedures and test results for fire protection Technical Specification *
surveillance requirements resulted in identification of the following
discrepancies:
a.
Testing of Diesel Fire Pump at Least Once Per Operating Cycle
Section 4.12.B.1.(e) of Technical Specification No. 3.12.B requires
that the station diesel fire pumps be demonstrated operable by per-
forming a system functional test which includes simulated automatic
actuation of the pumps throughout their operating sequence.
The
licensee's commitment in Section 3.5.E.2 of the Fire*Hazard Analysis
Report dated April, 1977, requires the fire pump installations to
conform to NFPA standard No. 20. This commitment states that a
plant modification would provide an adequate flow gage for full flow
testing of the pumps in accordance with NFPA standard 20.
The
licensee's surveillance procedure Nos. DFPP 4124-3 and DFPP 4124-4
were deficient in that:
(1)
The procedure required manual throttling of the pumps to achieve
the specific flows contained in Technical Specification 3.12.B.
and did not address automatic activation.
(2)
The procedures required testing the pumps to the specific head
and flow contained in the Technical Specification No. 3.12.B,
11
.. but failed to require testing for head and flow as specified in
-: :NFPI\\.- 20.:.. * .
{3')~~i~~e~~tir~~~!nt of quality affecting parameters such as pump
- *,t,;v.i'.bratioff under full flow conditions were not included in
- the test procedure or the test results.
(4) The test results were not compared to the origin.al manufacturer's
shop test curve or field acceptance test for the pumps because
neither of these curves were available to the licensee's staff.
b.
Testing of Water Suppression Systems at least Once Per Operating
Cycle
Section 4.12.B.1.(e) of Technical Specification No. 3.12.B requires
that fire suppression water systems be demonstrated operable by
performing a system functional test which includes simulated automatic
actuation of the systems throughout their operating sequence.
The
licensee's commitment in Section 3.5.E.3 of the Fire Hazard Analysis
Report requires that automatic sprinkler systems conform to NFPA
Standard No. 13.
The licensee's surveillance procedure No.
SP~4-6-39 failed to
incorporate appropriate test requirements to demonstrate the
sprinkler system is operable in accordance with NFPA 13 in that:
(1) The procedure didrnot require flow from the inspector's test
valve of wet sprinkler systems.
Instead, the alarm bypass
valve was used for this test.
(2) The procedure did not require flow from the two inch drain
valve of wet or dry systems.
Instead, the alarm bypass
valve was used for this test.
c.
Semiannual Testing of Fire Detectors
Section 4.12.A of Technical Specification No. 3.12.A requires that
the fire detection system be demonstrated operable by performing a
channel functional test every six months.
The licensee commitment
in Section 3.5.E.l of the Fire Hazard Analysis Report requires that
the fire detectQr system conform to the requirements of NFPA
Standard 720.
The licensee's surveillance procedure No. OFPP 4185-2 (Revision 4)
failed to incorporate the following quality affecting parameters as
required by NFPA 720:
(1) Periodic cleaning of detector units.
(2) Periodic adjustment for sensitivity (Section 3.1.2 of the
original SER required this test to be conducted).
12
- ~,.
.O*.
Accordjng_to.,:tb~,_.licensee
1 s staff, an independent fire protection
consu.}:t~n~;r-h.~s~;,'.been;-employed to review all technical specification
pro~ed~f~s;;:~tjc;t<t!!$t results to evaluate their adequacy in accordance
wi th;~Nf P~:f;s~~6cf~r.$1$;, and design requirements.
This assessment was in
progress;{~~:;~ttr~>tirne of the inspection and is expected to be comp 1 eted
by the end c>°f 1985.
Accardi ng to the 1 i censee, where necessary, the
procedures will be revised to coincide with the governing code and
design requirements.
This is considered an Open Item (237/85033-03; 249/85-029-03(DRS))
pending Region III 1s review of the licensee's actions.
No violations or deviations were identified.
5.
Administrative Controls - Control of Welding, Cutting, and Ignition
Sources
Licensee procedure No. OAP 3-11 (Revision 4) contained what appears
to be acceptable instructions for controlling storage of flammable and
combustible liquids, storage of compressed gas cylinders, and accumulation
of rubbish and transient combustibles such as wood scaffolding, etc. The.
procedure specifies housekeeping and cleaning responsibilities to be>
,r;f
followed by all employees and contractors.
'f
. ~~:: ..
No violations or deviations were identified in this area, however; the
inspectors cautioned the licensee on a proposed revision to welding and
cutting procedure No. DMP 41-00-1 that would include a provision to
facilitate ALARA concerns in high radiation areas.
The inspectors
informed the licensee that any relief from the requirements for a
firewatch to remain in the immediate area thirty minutes after cutting
and welding has been completed would have to be discussed with NRR.
6.
Quality Assurance Program
The licensee's commitment to Quality Assurance for fire protection is
documented in Section 3.3 of
11 Information Relevant to Fire Protection
Systems<<and Programs
11 and in letters to the NRC on this subject dated
January *24, February 24, March 20, and March 27, 1978, January 31 and
April 30, 1979.
The insp.ectors review of the licensee's Quality Assurance Program for
Fire Prot.ectfon. focluded review of the following:
a.
Eleven criteria applicable to fire protection that satisfy
Appendix A to Branch Technical Position 9.5-1 and supplement
guidance
11Nuclear Plant Functional Responsibilities, Administrative
Controls and Quality Assurance.
11
<.;
~*
b.
Quality Assurance Surveillance Reports dated September 3-6, 1985,
September 5-9, 1985, September 9-13, 1985, and September 16-30, 1985.
c.
Annual Quality Assurance Audits Nos. QAA 12-84-I dated April 17,
1984, and .. QAA 12-83-I dated April 15, 1983.
13
d.
Triennial. Audit by M&M Protection_ Consultants dated December 4, 1984.
No viOla~tiio:rfa or deviations were identified; however, the inspectors
suggest~d~t~(>. the licensee that for clarification, the statements made in
Section 3'~~3.-of the
11 Information Relevant to Fire Protection Systems and
Programs
11 should be modified to indicate their specific commitment to a
QA program to fire protection.
As written, this statement can be
interpreted to mean that the licensee committed to apply all of the
criteria of Appendix B in 10 CFR 50 to fire protection.
The inspectors determined that the licensee's practice of considering
fire protection as reliability-related is acceptable because this practice
ensures that all of the eleven criteria contained in the NRC's Guidance
are included in the program.
In addition, this practice allows for the
normal QA program for safety-related systems to be applied to fire
protection in it's entirety. Only one QA manual exists for reliability-
related systems and fire protection systems.
Although the licensee's Quality Assurance Program appears to be
.
effectively identifying issues that are contributing to hardware and
programmatic weaknesses, the licensee does not appear to be taking prompt
and effective corrective actions. This is exemplified by the remaining :t:
open items that have been identified in QA audits-and surveillances,
~
LERs, and NRC inspections. (This is further discussed in 3.b.(5) of thel
report.).
~
7.
Plant Tours
During tours of the plant, the inspectors observed the following
deficient conditions:
a.
Failure to Comply with* License Condition No. 2.B. of Amendment
No. 33 to Facility Operating License No. DPR-25 and Amendment
No. 36 to Provisional Operating License No. DPR-19.
Se~tion 5.1.6.6 of the original Fire Protection SER for Dresden Units
2(3 dated March 22, 1978 states that the licensee proposed the
installation of an automatic fire detection system to provide early
warning of a fire in the Refueling Floor Area in order to satisfy the
objectives of Criterion 3 of Appendix A to 10 CRF 50.
Amendment
No. 36 to Provisional Operating License No. DPR-19 (Unit 2) and
Amendment No. 33 to Facility Operating License No. DPR-25 (Unit 3)
da~ed October 1, 1980, require that the early warning automatic fire
detection system for the refueling floor area be installed by start
up following the 1979 Unit 3 refueling outage.
As of the date of this inspection (approximately six years after
start up following the Unit 3 1979 refueling outage) the licensee
has failed to comply with the provisions of Amendment No. 36 to
Provisional Operating License No. DPR-19 and Amendment No. 33 to
Facility Operating License No. DPR-25.
An early warning automatic
fire detection system fire detection system h~s not been installed
14
in, the .. Refueling Floor Area and no compensatory measures have been
. taken.'.;_a:s:* a* result of this decreased effectiveness of the plant's
.Jfr~1£ptcitection features.
- ~*~.--**~ <~.~~~:.-:~~=~-:~---~-~-* _:.**. -- -:(_
- * ** * **The:f~:ristal lation of an automatic early warning fire detection
system in the refueling floor area was not discussed in any of the
licensee's correspondence to the NRC that requested amendments to
modify the plant's fire protection Technical Specifications to
incorporate Limiting Conditions for Operation and Surveillance
Requirements for the fire protection modifications required by the
original SER for Dresden Units 2/3.
None of the proposed Tables
3.12.1 to Technical Specification 3.12 listed fire detection
instruments in the refueling floor area. However, sufficient
information- existed which should have alerted the licensee that
he was in violation of a license condition.
For example:
(1)
By letter dated February 25, 1980 (R. F. Janecek-CECO to
T. A. Ippolito-NRG) the licensee noted that they did not
believe installation of an automatic early warning fire
detection system in the refueling floor area was warranted
based on low fire loading and the ability to make up water
_
and cool the spent fuel pools in the event of a loss of either!
Unit's spent Fuel pool cooling equipment due to fire. This l:
letter did not request relief from the installation of a
~-
refueling floor fire detection system.
No official NRC
~
response was
issu~d for this letter.
(2)
By letter dated March 18, 1980 (L. Derderian-NRG to
M. Antonetti - Gage Babcock and Associates - Consultants
to the Licensee) the NRC referenced a March 17, 1980 telecon
record with T. Pickens (CECO) in which the following was agreed
to concerning Rea~tor Building Refueling floor fire detection
systems for Dresden Units 2/3 and Quads Cities Units 1 and 2:
(a)
The license was to confirm to the NRC that in the most
heavy fire loading situations (i.e. refueling periods),
the loading would not exceed that necessary to cause
structural failures.
(b)
The licensee was to confirm that structural concrete
protection extends from the floor to some specified
height, lessening the likelihood of structural failure.
(c) The licensee was to recalculate average combustible
loading subtracting out the pool areas.
The licensee could not provide the inspectors with documented
evidence that these issues were addressed.
This failure to followup on implementation of a license condition
is indicative of a programmatic breakdown which has resulted in
a reduced level of fire protection than was intended to satisfy
15
criterion 3 of Appendix A to 10 CFR 50 and is considered a
vioJatHm of Amendment No. 36 to Provisional Operating License
- No~~;iDEf~~19, Amendment No. 33 to Facility Operating License
No;;'.Jl,P,R;;.25,.10 CFR 50 (237/85-033-04; 249/85-029-04)(DRS).
'_-l, .... :::;' .~: -~
- -.:...::-~~ **. -;.
b.
Preparations for the Upcoming Extended Unit 3 Outage Separation of
Unit 1 from Units 2/3
c.
During plant tours and in meetings with the licensee during the
inspection, the licensee agreed to update their response to the NRC
and describe the administrative* controls and the actions that will
be necessary to isolate Unit 1 trom Units 2 and 3 since Unit 1 is
no longer operational but shares co1T111on areas with Units 2 and 3.
The inspectors also requested that the licensee describe those
administrative controls and actions that will be necessary to
separate common areas in Units 2/3 while Unit 2 is operating and
Unit 3 is in an extended outage.
This is considered an Open Item (237/85-033-05; 249/85-029-05)(DRS)
pending further review by Region II I. .
Self Contained Breathing Air Supply for the Fire Brigade
"-E
~
Section 3.4.D.4(h) of the document entitled
11 Information Relevant
~--*
to Fire Protection Systems and Programs
11
, requires that breathing
apparatus using full face piece positive pressure masks that are
approved by NIOSH be provided for the fire brigade.
)
The inspectors examined the fire brigade Scott Air Pak breathing air
cylinders that were provided on Fire Chart No. 2.
Four out of four
of these cylinders contained 1800 pounds of air pressure. According
to the licensee's staff, a minimum of 2200 pounds of air pressure
should be contained in each cylinder.
2400 pounds of air pressure
would indicate the cylinder is full and may provide a 30 minute air
supply for the average fire brigade member.
The cylinder gauges have
a_!ange of up to 3000 pounds of air pressure.
A December 1984 three year audit recommended that a set of written
instructions be provided at the breathing air cylinder filling
station to assure that the cylinders are filled properly. Filling
of the cylinders is the responsibility of Health Physics.
Due to
tirrie constraints, the inspectors were unable to contact Health
Physics to follow up this concern. Therefore, the licensee is
requested to provide at the site the appropriate acceptance criteria
for filling breathing air supply cylinders. This is considered an
Open Item (237/85-033-06; 249/85-049-06)(DRS) pending Region III
review of the licensee's breathing air cylinder filling procedures.
d.
300 Pound Fixed Cardox System Supply Tank First Floor, Turbine
Building
During plant tours, the inspectors observed the following
deficienc~es on the main C~ system storage tank located on
the first floor of the turbine buildings.
16
(1) The access door to the tank compressor motor was missing.
. '~'a');~:~Th_~:fglas-s' cover to the tank 1 s mercoid switch located inside
- --~'**~::t~?i};,:'.:t~~:;:;¥fg~~s door was missing.
- --:TR~:;~1\\:fdk*ii~ee ti-ad no explanation for these deficiencies, but agreed
to take immediate corrective actions.
This is considered an Open Item (237/85-033-07; 249/83-029-07)(DRS)
pending further verification of the licensee
1s corrective actions
by Region III.
8.
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 of licensee of both.
Open items disclosed during
the inspection are discussed in Paragraphs 4.c, 5.a, 7.b, 7.c, 7.d.
9.
Unresolved Items
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 insp~ction is discussed in Paragraph 3.c.
10.
Exit Interview
The inspectors met with the licensee representatives at the conclusion
of the inspection on October 4, 1985, and summarized the scope and
findings of the inspection.
The licensee acknowledged the statements
made by the inspectors.
The inspectors also discussed the likely
informational content of the inspection report with regard to documents
reviewed by the inspector during the inspection.
The licensee did not
identify any such documents as proprietary.
On October 21, 1985, in a
telephone conversation with the licensee additional concerns regarding
the lack of fire detectors on the refueling floor were discussed with the
1 icensee.
- ... *
17