ML17305B665

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Insp Repts 50-528/91-21,50-529/91-21 & 50-530/91-21 on 910603-12.Violations Noted.Major Areas Inspected:Fire Protection/Prevention Program
ML17305B665
Person / Time
Site: Palo Verde  
Issue date: 07/12/1991
From: Huey F
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML17305B663 List:
References
50-528-91-21, 50-529-91-21, 50-530-91-21, NUDOCS 9108050047
Download: ML17305B665 (23)


See also: IR 05000528/1991021

Text

Report Nos.:

Docket Nos.:

U. S.

NUCLEAR REGULATORY COMMISSION

REGION V

50-528/91-21,

50-529/91-21,

50-530/91-21

50-528,

50-529,

50-530

Licensee:

Inspection

Conducted:

June 3-12,

1991

Inspectors:

P.

H. Hadden,

Senior Fire Protection Engineer,

NRR

M. J.

Wagner

Reactor I spector,

RV

Approved by:

License

Nos.

NPF-41,

NPF-51,

NPF-74

Arizona Nuclear

Power Project

P.O.

Box 53999, Station

9012

Phoenix, Arizona

85072-2034

Facility Name:

Palo Verde Nuclear Generating Station

(PVNGS) Units 1, 2,

and

3

Inspection at:

Palo Verde Site, Mintersburg, Arizona

~Summar:

uey,

ngsneersng

ec )o

ae

s

e

Ins ection June 3-12

1991

(Re ort Nos. 50-528/91-21

50-529/91-21

Areas Ins ected:

One inspector

from the Office of Nuclear Reactor

egu

a son

an

one inspector

from Region

V conducted

an unannounced

inspection

to evaluate

the adequacy of the licensee's fire protection/prevention

program.

Inspection procedure

64704 was

used

as guidance during this inspection.

Results:

General

Conclusions

on Stren ths

and Weaknesses

Areas of Stren ths

Oedicated on-site fire department.

Fire watch program.

Areas

o'f Meaknesses:

a

Hot work permits for safe

shutdown plant areas

performed outside

containment

do not require the

same review and approval

as required for

hot work inside containment.

9108050047

910716

PDR

ADOCK 05000528

G

PDR

l

I

The provisions for identifying the thermalag fire barrier enclosures

required for Appendix

R and those required for Regulatory Guide 1.75

compliance

are confusing.

Si nificant Safet

chatters:

None

Summar

of Violations or Deviations:

One violation was identified for failure

o ma>nta>n

>re protec ion

eatures

required to protect safe

shutdown

capability.

0 en Items

Summar

Three

new items were opened.

Persons

Contacted

DETAILS

"R. Schaller, Assistant Plant Manager, Unit j.

  • R. Flood; Plant Manager,

Unit 2

  • R. Adney, Plant Manager,

Unit 3

"T. Braddish,

Compliance

Manager

  • C. Russo,

equality Control Manager

"R. Fullmer, Manager,

equality Audits and Monitoring

  • G. Overbeck, Director, Site Technical

Support

  • M. webster,

Manager,

Component Specialty Engineering

"M. Raddoccia,

Manager,

System Nuclear Engineering

Department

"D. Crozier, Fire Department Supervisor

  • F. Garrett,

Senior Consultinq Engineer,

Risk Management

"S. Burns, Project Manager,

Fare Protection

. "J. Austin, Fire Department

Deputy Chief

"M. Czarnylas,

Fire Department

Deputy Chief

"R. Fongemie,

Component

and Speciality Engineering Supervisor

  • D. Neal

Fire Protection

Engineer

"D. Douglas,

equality Assurance

Analyst

"D. Webb, equality Assurance Auditor

"C. Belford, Fire Department

Compliance Coordinator

"R. Fountain,

equality Assurance Auditor

"R. Bouqnot, equality Assurance

Auditor

  • R. Rouse,

Compliance Supervisor

  • S.

Lopez,

System Engineer

"N. Minson,

System Engineering Supervisor

"P.

fin, Compliance

Engineer

"S. Kanter, Arizona Public Service Site Representative

"S. Draper,

Southern California Edison Site Representative

"K. Hall, El Paso Electric Site Representative

P. Caudsll, Director, Site Services

K. Clark, Licensing Engineer

R. Prabhakar,

Manager,

equality Engineerinq

H. Bieling, Manager,

Emergency Planning/Fsre

Department

E. Kleinsorg, Fire Protection

Engineer

M. Karbassian,

Supervisor,

Mechanical

Engineering

C. Foster,

Mechanical

Engineer

R.

Robb, Senior Mechanical

Engineer

B. Harrison, Senior Mechanical

Engineer

The inspectors

also interviewed other licensee

employees

during the course of

the inspection.

  • Denotes those attending the Exit Meeting on June 7, 1991.

E

~

'

2.

Fire Protection/Prevention

Pro

ram (64704)

a.

Administrative Controls Procedure

Review

In the area of combustible material controls

and fire hazard

reduction,

the inspectors

reviewed procedure

14AC-OFP03,

Control of

Transient Combustibles,

Revision 1, Effective Date 7-13-90.,

The

inspectors

found that this procedure

placed controls over the

use of

ordinary combustibles,

and flammable/combustible

gases

and liquids.

The procedure restricts the use of non-fire retardent treated

wood

in safety related areas,

controls the use of transient ordinary

combustibles,

flammable/combustible

gases

and flammable/combustible

liquids by the use of a Transient

Combustible Control Permit (TCCP).

In addition, this procedure

requires the

use of Underwriters

Lab/Factory Hutual

(UL/FM) approved fire safety cans for handling of

flammable/combustible

liquids, flammable/combustible liquid storage

cabinets,

and trash/waste

cans for the collection of ordinary

combustible waste (i. e. rags).

The .inspectors,

noted that Section

3.6. 10 states that flammable/combustible

liquids in quantities

greater

than one gallon shall not be used in a safety related area

unless

monitored by the

TCCP.

This appears

to be inconsistent with

the guidance

provided in Section 3.6.5.5.

which requires

a

TCCP to

be issued for quantities of combustible/flammable

liquids exceeding

one cumulative gallon.

The inspectors

were concerned,

that as

a

result of misinterpretation,

Section 3.6.10 could allow cumulative

quantities

exceeding

one gallon of flammable liquid into a plant

area important to reactor safety without being reviewed under the

TCCP process.

The licensee

agreed that the intent of this section

~s not clear and agreed to clarify the requirement during a

subsequent

revision to this procedure.

In addition, the inspectors

verified that this procedure controlled the use of plastic sheeting

material

and used=plastic

sheeting materials which had fire

retardant properties.

The licensee,

for the selection of plastic

sheeting materials,

follows American Nuclear Insurers flammability

guidance,

which is an acceptable

practice.

In the area of ignition source/fire risk reduction,

the inspectors

reviewed Procedure

14AC-OFP06,

Hot Mork Authorization, Revision 1,

Effective Date 5-18-89.

This procedure

provides

an adequate

level

of control over hot work operations.

The inspectors

found that the

procedure

required combustibles

in the area of the 'hot work to be

moved at least

35 feet away from the operation or be properly

covered with fire retardant welding blankets.

Fire watches

are

appropriately

used whenever fire preventive

measures

can not be met.

In addition, the inspectors verified that the hot work permit is

valid for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />

when the plant is in operational

modes I, II, or

III.

The inspectors

also reviewed procedure

14DP-OFPOl, Fire Match

Requirements,

Revision 0, Effective Date 9-8-89.

The inspectors

interviewed four fire watches

(three continuous

and one roving).

The inspectors

found fire watch personnel

to have

a sufficient level

of know1edqe with regard to what actions they are to perform in the

event of discovering

a potential fire condition.'n addition, the

inspectors

noted that fire watch personnel

had

a good understanding

of the fire protection

impairments in the area,

and were fully

familiar with the use of portable fire extinguishing equipment.

At

the time of this inspection,

the inspectors

were aware that the

licensee

was reviewing training records

as discussed

in Inspection

Report 50-528/91-19.

Surveillance

Procedures

The inspectors

reviewed procedure

14DP-OFP15,

Backup Fire

Pump

Installation,

Revision 0, Effective Date 5-6-89.

The purpose of

this procedure is to provide guidelines for the installation of the

backup fire pump (station fire truck) when one or more of the three

station fire pumps

becomes

inoperable.

Mhen the backup fire pump is

required,

the station fire truck is sent to the cooling tower intake

canal

and set

up for drafting operations.

The pump's four 2 1/2

inch discharge outlets are connected to the fire water main intake

connection

vsa four 2 1/2 inch fire hose lines where the

pump is

maintained in standby until directed to operate

by the shift fire

captain.

The inspectors

were concerned with the verification of

operability of the backup fire truck fire pump.

This procedure

does

not verify the operability of the fire pump on the fire truck (i.e.,

ability to draw a prime, )n order to develop required flow and

pressure) prior to being connected to the underground. fire main

system via the intake connection.

The licensee

agreed to revise the

procedure to address verification of fire pump operability.

In addition, the inspectors

reviewed procedures

14FT-OFPOl, Diesel

Driven Fire

Pumps Start

and

Run, Revision 2, Effective Date 5-15-90

and 14AC-OFP09,

C02 Fire Suppression

System Valve Position

~rification, Revision 1, Effective Date 10-24-90.

The inspectors

did not identify any concerns

and found these

procedures

to be

adequate.

Fire Bri ade Readiness

The inspectors

reviewed the content of the classroom instruction

provided to the fire brigade

by reviewing the following lesson plans

and course outlines:

NPF16-00-XP-001-00,

Revision Date ll/21/90, Confined Space

Drill;

NPL02-01-RC-001-00,

Revision Date 8/13/90, Ventilation;

NPL05-01-RC-001-00,

Revision Date 8/29/90, Mater Supply;

NPL10-01-RC-001-00,

Revision Date 8/17/90, Sprinklers;

NPL18-00-RC-001-00,

Revision Date 3/1/90, Fire Behavior;

NPF42-00-RC-001-00,

Revision Date 12/17/90,

Types of Fires

and

Hazards at

PVNGS;

and

NPF46-00-RC-001-00,

Revision Date 12/17/90,

Elements that

Define the Plant Fire Protection

Program.

This review verified that the fire brigade

lesson plans were

properly structured

and organized.

However, the technical

content

of the lesson

plans

and outlines focused

on the generic principles

of fire fighting which are applied routinely to non-nuclear

applications.

The inspectors

discussed

with the licensee that

nuclear plant fire protection problems

and hazards,

such

as fire in

the electrical

switchgear

room, are unique and should

be discussed

in detail during various lessons.

The licensee

recognized

these

concerns

and indicated that they would resolve

them 8uring

subsequent

revisions to the lesson plans.

The inspectors

witnessed

an unannounced fire brigade drill.

The

scenario

was fault/explosion/fire in a piece of safety related

switchgear in the Unit 1 "B" switchgear

room on elevation

100-0 of

the control building.

The initiation of the drill was unique in

that the drill statement,

which identified the initial conditions of

the fire, was. given to the actual fire watch person performinq fire

watch duties in the "A" switchgear

room (Note - During the dn 11 the

fire watch who participated

was relived by another qualified fire

watch).

The fire watch reacted to the drill and promptly went to

the phone

a'nd notified the control

room via the emergency

number.

The fire watch then returned to the area adjacent to the entrance of

the "B" switchgear

room to await the arrival of the fire brigade.

Upon arrival of the brigade,

the fire watch reported the observed

fire conditions to the brigade captain.

During the drill the 'inspectors

evaluated

the fire brigade for

adequate

performance

in the following areas:

Protective clothing properly utilized;

Self contained breathing

apparatus

(SCBA) properly utilized;

Hose lines properly deployed

and utilized;

Entry into the fire room don'e properly;

Assessment

of fire brigade leaders direction, thoroughness,

accuracy,

and effectiveness

during the fire fighting effort;

Adequacy of radio communications with control

room;

Checking for fire extension;

Utilization of the fire fighting pre-plans/strategies;

Adequacy of smoke removal operations

performed by the fire

brigade;

and

Manual fire fighting equipment sufficient to properly and

efficiently perform the required fire fighting operations.

The inspectors

noted

good performance

by the fire watch who reported

the fire.

In addition, the inspectors

observed

good fire brigade

team work and good cooperation

and information exchange

between the

operations fire technical

advisor

and the fire brigade captain

(leader).

The inspectors

found security response

and control of the

areas

around the fire fighting activities to be effective and

efficient.

During the dri11,

communica

iona between the control

room and the fire scene was'ound

to be'ffective.

The inspectors

noted that the drill participants

played their designated

roles

effectively-and

responded

appropriately to drill artificialities.

However, the inspectors

observed

areas of the fire briqade's

performance

on which the licensee

needs to focus addit>onal

attention.

The inspectors

observed that the method for getting fire

fighting support equipment to the fire scene

could be improved.

Hu)tiple trips had to be

made

by one brigade

member in order to get

the required

equipment

on the scene.

Th>s appears

to be an

ineffective use of limited fire fighting resources.

In addition,

the inspectors

noted that the search

and rescue

techniques

were

basic

and more advance

techniques,

such

as personal lite line

techniques,

would improve the efficiency and effectiveness

of-this

operation.

The inspectors

expressed

concern regarding

communications

between the fire brigade

members in the fire room and

the fire brigade captain.

The radios currently used

by the brigade

do not use lapel type microphone/speakers

and the turnout coats

are

not equipped with radio pockets.

Fire brigade

members,

in order to

communicate

and receive orders,

are currently required to hold the

portable radios

near their .heads in order to listen.

This type of

communication occupies

the use of one arm and hand to hold the radio

and lends itself to loss of the radio in low visibility areas.

Loss

of the radio occurs

when the radio is set

down in order to perform

fire fighting operations.

With the

use of lapel

microphones/speakers

along with a radio pocket

on the turnout coat,

use of the arm and hand is regained, fire fighting operations

can

continue

more effectively, and communications

can

be maintained with

the fire fighting forces

more efficiently.

In addition, the

inspectors

noted additional

communication

concerns.

Communications

distortion was noted between

brigade

member to brigade

member

and

brigade

member to radio microphone when'wearing se'If contained

eathing apparatus

(SCBA).

The

SCBA used

by the fire brigade

does

riot incorporate

voice amplification devices;

The inspectors

were

also concerned with the deployment of the fire attack

hose line.

The hose line was extended with the standpipe

pack at the point of

entry to the fire room.

Under these drill conditions,

the fire hose

line was not charged with water and

made this operation

and the

advancement

of the hose into the fire room possible.

However,

under

this hose configuration, if the hose line was charged with water,

the brigade would have

had great difficulty in advancing the hose

into'he fire room.

These observations

and concerns

regarding

communication, life line techniques,

hose line deployment,

and

movement of support equipment,

were received favorably by the

licensee.

The licensee

indicated that each concern would be

addressed

and corrective action taken

as warranted.

The inspectors

found the overall performance of the fire brigade to

the drill scenario to be satisfactory.

Plant Tour and Ins ection of Plant Fire Protection Features

The inspectors

toured the following 'plant areas:

fire pump house;

the Unit j. Auxiliary buHding, main steam structures

and the

radiological controlled area;

the Unit 2 turbine building, diesel

generators

A and B, control

room,

and the upper

and lower cable

spreading

rooms;

and Unit 3 turbine and control buildings.

0

I

0

During this tour the inspectors visually inspected

the fire

protection equipment/features

provided in these

areas

and the

adequacy of the licensee's fire prevention

program from a

performance

based perspective.

On these tours the inspectors

visually verified the following:

Transient combustibles

properly controlled;

Flammable

and combustible liquids, including hazardous

chemicals,

properly controlled;

-Melding, cutting, grinding, and open flame operations

controlled;

Housekeepinq

properly maintained;,

Fire detection

operable with no indications of system trouble;

Manual fire hose stations

operable

and appear in good working

condition;

Portable fire extinguishers

operable;

Automatic suppression

systems

operable

and in good material

condition; and

Fire barr>ers

(doors, penetration

seals, fire dampers)

and

cable

raceway

and equipment fire barriers operable.

The inspectors

observed

the following conditions (discussed

further in

subsequent

paragraphs):

The material

and housekeeping

conditions in the fire pump house

'ere

considered

to be below average.

In the Unit 3 turbine building, the directional water spray

nozzles for the turbine bearing fire suppression

system were

not properly aimed at the bearing assembly.

Thermal fire

detectors

over the main feedwater

pumps were not properly

.

aligned over the hazard.

In the Unit 1 "B" auxiliary feedwater

pump room,

raceway fire

barrier (thermolag) for train "A" auxiliary feedwater conduits

ARK 70 and 71 was breached..

In the Unit 1 Main steam support structure

on the 100'-0"

elevatioh,

the support for junction box 1EZCAEBKKJ11 was not

properly protected

by thermolag fire barrier material.

It was noted that, overall, the material condition of the fire

protection features

and the housekeeping

in the Unit 1

radiation controlled area

(RCA) and the cable spreading

areas

were above average

when compared to the features

provided and

the housekeeping

in the main steam support, turbine building,

and fire pump house structures.

In the Unit 1

RCA on the 120'-0" el,evation,

channel

"D"

electrical penetration

room, protecto wire thermal detector,

for cable tray lEZA1BNTXA, installation discrepancies

were

noted.

In Unit 1, channel

"D" electrical penetration

room, spare

embedded'onduits

lEZA2BDRK07 and

1EZA2BDRK09 located in the

east

2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> fire barrier-wall separating fire area

47B from

fire area

52D were not.provided with metal conduit plugs.

Thermolag fire barriers for Regulatory Guide (RG) 1.75

compliance were'ot easily identifiable from those required for

Appendix

R compliance.

The licensee

was responsive

to the conditions identified in the fire pump

house.

The licensee

s actions, prior to the completion of this

inspection,

included steam cleaning of piping and the

pump rooms,

removing fuel oil contaminated

water from the diked areas

under the

outside fuel oil tanks,

and initiating efforts to paint the fire

protection piping in the rooms.

During the walkdown of the Unit 3 turbine building, the inspectors

noted

fire protection system configuration control concerns

associated

with the

water spray nozzles protecting the turbine bearings

and the thermal fire

detectors

installed over the main feedwater

pumps.

The water spray

nozzles

were not properly aimed at the bearing assemblies.

The

inspectors

noted that the misaligned configuration could affect the fire

control

and suppression

efficiency of the system.

The inspectors

also

noted that the thermal detectors for the main feedwater

pumps were not

properly aligned over the hazard.

The detector

probe

and heat collector

were not in a position which would provide optimum response.

In the

judgement of the inspectors,

the detectors

would have responded

to a

fire, however,

a time delay would have

been associated

with the response.

The pensee

noted the inspectors

concerns

and indicated that they would

correct these conditions.

Future inspections will be conducted to assess

whether the licensee's

programs

are sufficiently complete in providing

details regarding the directional alignment of spray nozzles

and

detection

equipment.

This is identified as Followup Item

50-528/91-21-02.

The inspectors

performed

a walkdown of thermolag fire barrier assemblies

required for compliance with Appendix R,Section III.G.

During this

walkdown the inspectors

noted in the Unit 1 "B" auxiliary feedwater

pump

room that the thermolag fire barrier protecting train "A'uxiliary

feedwater conduits

ARK 70 and 71 was breached.

The inspectors

requested

the licensee

to verify that this Appendix

R barrier impairment was noted

on the plant's Fire System Impairment

Log and that this impairment was

identified on the fire watch fire system

impairment log sheet.

The

licensee verified that this impairment was not identified in the plant

fire system

impairment log and was not identified as

an impairment

covered

by the current roving fire watch which was patrolling the "B"

auxiliary feedwater

pump room.

The licensee fire protection staff was

not aware of this impairment and the appropriate

compensatory

measures

for this specific impairment were not implemented.

The inspectors

reviewed Mork Request

(MR) 778204 which removed the thermolag fire

barrier material in order to remove

an

HVAC spool piece for a dapper

inspection.

According to procedure

14AC=9FP02, Fire Barrier Seal

and

Structural

Steel Fireproofing

Removal

and Reinstallation,. Section

3. 1.5

and 3. 1.6 requires that the work control groups

ensure that

an approved

r

0

Fire Barrier Seal

Removal

Request

(FBSRR) is included in the

WR, and the

work group notify fire protection of the fire barrier breach.

The

inspectors verified that

a

FBSRR was not included in the

MR and fire

protection

was not notified as required

by the procedure.

The work

associated

with this request

was,completed

on October 31,

1990.

On

November 7, 1990, the licensee

issued

MR 779210 to reinstall the

thermolag fire barrier material

on the affected conduits.

.At the time of

the inspection, this

WR had not been scheduled to be worked.

As a result

of this condition the licensee

issued Material Nonconformance

Report

(NNCR) 91-FP-2044.

Palo Verde Unit 1 Operating

License

NPF-41, License

Condition

C (7), Fire Protection

Program,

requires the licensee to

implement and maintain in effect all provisions of the approved fire

protection.

The approved fire protection program, including the

requirements

of 10 CFR 50 Appendix R, Section III.G.2.c., was not

maintained.

Redundant

systems

required for safe

shutdown were not

adequately

protected against fire in the train "B" auxiliary feedwater

pump room.

Failure to maintain fire protection features

required to

rotect safe

shutdown capability is identified as

an apparent violation

0-528/91-21-01.

During the tour of the Unit 1 main steam support structure

(HSSS) the

inspectors,

in conjunction with the licensee,

identified a support for

electrical junction box lEZCAEBKKJll that was not protected in accordance

with UFSAR Section 9.B.2. 12.1. c, Deviation 6 (Page 9B.2-331).

This

UFSAR

section requires that intervening steel

which comes in physical contact

with the protected

raceway shall

be protected with thermolag

for a

distance of 8 inches

from the point of contact with the raceway to

provide the protection envelope

needed to meet the required fire rating.

As a result of this condition the licensee

issued

NNCR 91-FP-2046

and

fir6 impairment 1-91-126.

The inspectors

consider this'ssue

to be

licensee identified and will followup o'n their corrective actions during

a subsequent

NRC inspection.

In touring the Unit 1

RCA the inspectors

noted that overall the material

conditions of the fire protection features

and the housekeeping

was above

, average

when compared to the features

provided and the housekeeping

in

the main steam support, turbine building, and fire pump house structures.

On elevation 120'-0" of the

RCA, in the channel

"D" electrical

penetration

room, the inspectors,

in conjunction with the licensee,

identified that spare

embedded

conduits

(lEZA2BDRK07 and

1EZA2BDRK09)

were not provide with metal conduit plugs in accordance

with drawing

13-E-ZAC-050, Revision 24, Note 3.23.

The drawing requires that all

spare

embedded

conduits penetrating fire rated floors and walls be sealed

with metal plugs at both ends.

As a result of this condition the

licensee

issued

WCR 91-FP-2043.

The inspectors

consider this issue to

be licensee identified and will followup on their. corrective -actions

during a subsequent

NRC inspection.

In addition, during this tour, the inspectors

and the licensee identified

a configuration concern associated

with the protecto wire thermal

detector in cable tray 1EZAlBNTNA.

The detector

was noted hanging

outside of the cable tray and not installed in a criss-cross

fash>on

across

the cabling in the tray as required.

As a result of this

condition, the licensee

issued

MNCR 91-FP-2045.

The inspectors

consider

0

I

this issue to be licensee identified and will followup on their

corrective actions during a subsequent

NRC- inspection.

During the walkdowns

and inspection of the electrical

raceway fire

barrier enclosures

(thermolag) required for Appendix

R compliance,

there

was confusion in some plant areas

by the licensee

s staff, in identifying

the thermolag fire barrier enclosures

required for Appendix

R and those

required for RG 1.75 compliance.

Appendix

R fire barriers

have

a

specified fire rating,

dependent

upon the period of resistance

to a

standard fire exposure,

of 1-hour or 3-hours

as applicable for fire

protection to ensure

safe

shutdown capability.

RG 1.75 fire barriers,

required for electrical

separation,

are not fire rated,

nor are the

barrier structures

required to be maintained at the

same quality level of

integrity as the Appendix

R barriers.

The inspectors

were concerned

from

a performance

based

inspection perspective that neither the licensee's

staff or NRC inspectors

could readily identify thermolag fire barrier

enclosures

required for Appendix

R compliance.

The inability to identify

these barriers,

through routine visual inspection techniques,

without

engineering

support documents,

decreases

the efficiency of identifying

fire barrier deficiencies

by plant personnel

not familiar with the

fire/safe

shutdown analysis.

Currently, without the in plant

identification of these barriers,

the safety significance of these

barriers

and the importance of there integrity ss not recognized

by

non-fire protection plant personnel.

The licensee

concurred with the

inspectors

finding and indicated that they would develop

a method to

field identify the Appendix

R barriers

and those required to meet

RG 1.75.

The verification method for field identification of Appendix

R

.

thermolag fir'e barriers

amd

RG 1.75 required thermolag barriers is

iden+fied

as Foll swop Item 50-528/91-21-03.

e.

Fire Protection

ualit

Assurance

3.

The inspectors verified that the required annual,

biennial

and triennial

audits of the fire protection program wer'e performed.

The annual audit

(Report

No.88-018)

was performed August 8, 1988 through August 29,

1988

by the equality Audits and Monitoring Department

(gAQl).

One of the five

team

members

was

a technical specialist in the area of fire protection.

Audit Report

No.89-018 documents

the biennial audit performed

by gAEA

during the period of August 7-31,

1989.

The biennial audit team was

composed of -eleven

team

members.

The triennial audit,

documented

in

Audit Report

No.90-016, consisted of five full time auditors

and four

part time auditors;

the audit was performed August 6, 1990 through

September

14,

1990.

The triennial included

an outside

independent fire

protection consultant

as required

by Technical Specifications Section 6.5.3.5(g).

These audits provided

a comprehensive

evaluation

and

assessment

of the performance

and effectiveness

of the implementation

of.

the fire protection program.

Exit Meetin

The inspectors

met with the licensee

management

representatives

denoted

in paragraph

1 on June 7, 1991.

The scope of the inspection

and the

findings as described

in this report were discussed.

Also documented

in

0

t

10

Section 2.e of this report are the findings of information reviewed in

the region

on June

12,

1991.