ML20003J110

IE Insp Repts 50-254/81-04 & 50-265/81-04 on 810223-27. Noncompliance Noted:Failure to Establish Fire Watch in Area of Welding Operation Above safety-related Cabling

ML20003J110
Person / Time
Site:	Quad Cities
Issue date:	03/31/1981
From:	Baker K, Grobe J, Williams C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20003J103	List: ML20003J102 ML20003J110
References
50-254-81-04, 50-254-81-4, 50-265-81-04, 50-265-81-4, NUDOCS 8105080457
Download: ML20003J110 (18)

See also: IR 05000254/1981004

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U.S. NUCLEAR REGULATORY COMMISSION

OFFICE OF INSPECTION AND ENFORCEMENT

REGION III

Report No. 50-254/81-04; 50-265/81-04

Docket No. 50-254; 50-265

License No. DPR-29; DPR-30

Licensee: Commonwealth Edison Company

P. O. Box 767

Chicago, IL 60690

Facility Name: Quad-Cities Nuclear Power Station, Units 1 and 2

Inspection At: Quad-Cities Site, Cordova, Illinois

~ Inspection Conducted: Febr ary 23-27, 1981

30 b

Inspectors:

J. A. Grobe

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K. R. Baker

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Approved By:

C. C. Williams, Chief,

Plant Systems Section

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Inspection Summary

Inspection on February 23-27, 1981 (Report No. 50-254/81-04; 50-265/81-04)

Areas Inspected: Routine, unannounced inspection to review the implementa-

tion of the licensee's housekeeping program and fire prevention / protection

program including review of fire fighting equipment and systems, fire

prevention and protection administrative controls and general employee,

contractor and fire brigade training. The inspection involved 35 inspector-

hours onsite by one NRC inspector including 0 inspector-hours onsite

during offshifts.

Results:

Of the three areas inspected, no apparent items of noncompliance

were identified in one area; four apparent items of noncompliance were

identified in two areas (open fire barrier penetration

paragraph 2;

failure to follow welding procedure - paragraph 3; failure to follow

radiation control procedure

paragraph 3; failure to follow-housekeeping

procedure

paragraph 3).

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DETAILS

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Persons Contacted

• N. J. Kalivianakis, Plant Superintendent

• R. L. Bax, Assistant Superintendent of Maintenance - Fire Marshall

• J. R. 'Junderlich, ~ Technical Staff

• R. A. Flessner, Technical Staff

• K. J. Hansing, Lead Quality Assurance Engineer

T. B. Pettit, Maintenance Foreman - Assistant Fire Marshall

J. B. Heilman, Quality Assurance Engineer

H. K. Huisingh, Training Instructor

E. E. Cole, Training Instructor

F. J. Geiger, Training Supervisor

D. L. Gilbert, Engineering Assistant - Instrumentation

P. Skiermont, Radiation Protection Foreman

A. P. O'Horo, Rad / Chem Technician

D. G. Vanpelt, Master Electrician

• D.

F. Thayer, Maintenance Staff Assistant

I. Frischkorn, Stationmen Foreman

G. J. Demos, Stationmen Foreman

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• Denotes those persons in attendance at the exit interview on

February 27, 1981.

2.

Fire Protection Equipment and Systems

a.

Manual Fire Fighting Equipment

The inspector examined the licensee's manual fire fighting equip-

ment including selected hose and standpipe stations, fire extin-

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guishers, self-contained breathing apparatus, protective clothing,

AFFF foam and applicators and other equipment available for fire

fighting. The equipment availability was reviewed using commit-

ments contained in the Fire Protection Safety Evaluation Report

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(FPSER) issued July 27, 1979 with supporting' licensee transmittals,

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the fire hazards analysis and the plant technical specifications.

(1) Areas of Inspection

(a) Procedures

Number

Title

Dates

QMS 100-1

Monthly Fire Inspection

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QMS 100-S1

Checklist for Procedure

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QMS 100-1

6/80, 11/80, 12/80

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QMS 100-S2

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QMS 100-S13

1/80, 2/80, 3/80

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4/80, 5/80, 6/80,

7/80, 8/80, 9/80,

10/80, 11/80, 12/80'

QMS 100-S26

5/80, 11/80, 12/80-

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QMS 100-S27

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QMS 100-S28

QMS 100-6

Annual Fire Hose

Inspection

QMS 100-S14 Checklist for Procedure

10/80

QMS 100-6

QMS 100-9

Fire Hose Hydrostatic

Test Procedure

QMS 100-S19 Group B Checklist for

9/80

Procedure QMS 100-9

QMS 100-15

-CO, Hose Reel

Functional Test

QMS 100-S24 Checklist for Procedure

10/80 (Unit 1)

QMS 100-15

QOS 4100-3

Monthly fire Protection

System Inspection

QOS 4100-S2 Checklist for Procedure

11/80, 12/80

QOS 4100-3

1/81, 2/81

QRP 100-17

Self-Contained Breathing 7/80, 8/80

Apparatus Monthly

9/80, 10/80

Inspection

11/80, 12/80,

1/81, 2/81

Annual Fire Extinguisher

Tags

1980

(b) Plant Tours

The inspector examined manual fire fighting equipment

during tours of the following areas:

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Screenhouse

Unit 1 Reactor Building

Unit 2 Reactor Building

Turbine Building

Plant Yard

(2) Findings

(a) Violations

No apparent items of noncompliance were identified in

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this area.

(b) Fire Protection Modifications

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The following modifications identified in the FPSER

cppear to have been satisfactorily completed:

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3.1.6

Foam Suppression Systems: Manual Equipment

3.1.7-

Portable Extinguishers

3.1.12 Protective Clothing

~3.1.13

Air Breathing Equipment

(3) Discussion

(a) Unresolved Item (50-254/81-04-01; 50-265/81-04-01)

The fire hoses listed below located in the radwaste

building, off gas filter building, resin solidification

building, and maximum recycle area had their last

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hydrostatic test between five to twelve years ago.

The NRC position on frequency for hydrostatic testing

of interior hoses important to safety is testing on

three year intervals.

Hose Station Number Years Overdue for Hydrostatic Test Based

on 10 CFR 50 Appendix R Requirements

3-1-1F-3

2

3-2-9F-3

7

3-3-11F-3

8

3-7-12F-3

3

3-7-15F-3

8

3-2-2F-22

9

3-1-1F-14

9

3-1-3F-20

2

3-2-4F-20

2

During the inspection the inspector expressed concern

that the pressure boundary integrity of these hoses

may be degraded. A determination of the acceptability

of these hoses will be made after more information is

obtained concerning licensee commitments in this area.

(b) The inspector expressed the following concerns to the

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lice..see either during the inspection or at the exit

interview:

1.

Fire hose station 2-2-43F-2 had been apparently

accidentally omitted from checklist QMS 100-S19

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for surveillance procedure QMS 100-9.

The licensee indicated that this station would

be added to the checklist. The inspector verified

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that the hose station had received the required

surveillance.

2.

The following carbon dioxide fire extinguishers

located in the plant are one year overdue for

hydrostatic testing:

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2-2-45-2

1-2-39-6

1-2-8-2

2-1-35-2

1-2-42-6

1-2-9-2

1-1-13-2

1-3-48-6

1-2-4-2

2-2-42-2

The licensee has the extinguishers scheduled for

testing this year.

3.

Hose station 2-4-5F-6S was partially obstructed

from use by a large roll of rubber hose. The

licensee indicated that obstruction would be

eliminated.

b.

Automatic Fire Detection, Suppression and Emergency Systems.

The inspector examined the licensee's automatic fire detection,

suppression and emergency systems including the fire water system,

cardox system, foam system, detection system, penetration fire

barriers, fire doors, and emergency lighting. These systems were

reviewed using commitments and requirements in the FPSER with

supporting licensee transmittals, the fire hazards analysis, and

the plant technical specifications.

(1) Areas of Inspection

(a) Procedures

Number

Title

Dates

QMS 100-8

Semi Annual Exterior Hose Cabinet Flush

and Valve Cycle Test

QMS 100-S17 Checklist for Procedure QMS 100-8

5/80, 10/80

QMS 200-2

Semi Annual Inspection and Test of Eme rgency

Light Power Packs

QMS 200-S1

Checklist for Procedure QMS 200-2

7/80, 2/81

QMS 100-7

Annual Interior Fire System Flush and

Valve Cycle Test

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QMS 100-S15 Checklist for Procedure QMS 100-7

11/80

QMS 100-S16 Checklist for Procedure QMS 100-7

11/80

QMS 100-10

Annual Sprinkler Header and Nozzle

Inspection

QMS 100-S21 Checklist for Procedure QMS 100-10

3/80

QMS 100-16

Annual Transformer Deluge Systems Flush

QMS ,100-S25 Checklist for Procedure QMS 100-16

7/80, 8/80,

10/80

QMS 100-17

Fire System Flow Test

QMS 100-S3

Checklist for Procedure QMS 100 .

8/80

QMS 100-18

Sprinkler Air Flow Test

8/80

QMS 100-12

Deluge Sprinkler System Functional Test

QMS 100-S5

Checklist for Procedure QMS 100-12

10/80 (Unit 1)

QMS 100-13

Wet Pipe Sprinkler System Functional Test

QMS 100-S6

Checklist for Procedure QMS 100-13

10/80 (Unit 1)

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Number

Title

Date

QMS 100-11

Diesel Fire Pump Battery Inspection

QMS 100-S22

Checklist for Procedure.QMS 100-11

10/80

QMS 100-14

Diesel Fire Pump Inspection

QMS 100-S2?

Checklist for Procedure QMS 100-14

10/80

QOS 4100-1

Monthly Diesel Fire Pump Test

QOS 4100-S1

Checklist for Procedure QOS 4100-1

10/80, 11/80,

12/80, 1/81

QOS 4100-2-

Annual Water and Sprinkler System Valve

Operability

QOS 4100-S12

Checklist for Procedure QOS 4100-2

5/79, 10/80

QOS 4100-4

Monthly Fire Suppression Valve Position

Inspection

QOS 4100-S3

Checklist for Procedure QOS 4100-4

3/80, 4/80, 5/80,

6/80, 7/80, 8/80,

9/80, 10/80,

11/80, 12/80, 1/81~

QOS 4100-5

Fire Protection Weekly Inspection

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QOS 4100-S4

Checklist for Procedure QOS 4100-5

10/80 - 1/81

(weekly).

QOS 4100-6

Fire Suppression Water System Functional Test

QOS 4100-S10

Checklist for Procedure QOS 4100-6

10/80

QOS 4100-7

Diesel Fire Pump Capacity Test

10/80

QTS 170-1

Surveillance of Penetration Fire Stops

QTS 170-S1

Checklist for Procedure QTS 170-1

1978, 1979

QIS 56-1

Records Storage Building Semi Annual

Fire Inspection

QIS 56-S1

Checklist for Procedure QIS 56-1

4/80, 10/80

QIS 57-1

Cable Spreading Room /HVAC Fire Protection

Surveillance Procedure

QIS 57-S1

Checklist for Procedure QIS 57-1-

4/80, 10/80

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QIS 57-S2

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QIS 57-S3

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QIS 57-S4

QIS 57-S5

Checklist for Proc dure QIS 57-1

4/80, 10/80

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QIS 57-S6

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QIS 57-S7

QIS 58-1

Standby Diesel Generator Cardox Fire

Protection Test Procedure - Semi Annual

QIS 58-S1

Checklist for Procedure QIS 5F,-1

4/80, 10/80

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QIS 58-S2

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QIS 58-S3

QIS 59-1

Standby Diesel Generator Cardox Fire

Protection Test Procedure - Outage

QIS 59-S1

Checklist for Procedure QIS 59-1

10/80 (Unit 1)

QIS 59-S2

10/80 (Unit 1)

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QIS 59-S3

10/80 (Unit 1)

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(b) Plant Tours

The inspector examined automatic fire detection,

suppression, and emergency systems during tours of the

following areas:

Screenhouse

Unit.1 Reactor Building

Unit 2 Reactor Building

Turbine Building

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(2) Findings

(a) Violations

Noncompliance (50-254/81-04-02; 50-265/81-04-02)

Technical Specification 3.12.F.1 states:

"All penetration fire barriers protecting safety

related areas shall be intact except as stated in

Specification 3.12.F.2."

Technical Specification 3.12.F.2 states:

"With one or more penetration fire barriers not

intact, establish a continuous fire watch on at

least one side of the affected penetration within

one hour if the area on either side of the affected

penetration contains equipment required to be operable.

Contrary to the above, during plant tours, the inspector

observed one penetration fire barrier which was not

intact with no apparent fire. watch in the area.

A penetration in the three-hour rated fire barrier

between the Unit 1 and Unit 2 Reactor Buildings on

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the 595' level above the fire door was open and

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unattended.

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(b) Fire Protection Modifications

The following modification identified in the FPSER

appears to have been satisfactorily completed:

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3.1.3 Yard Hydrants: Semi Annual Surveillance

(3) Discussion

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(a) Unresolved Item (50-254/81-04-03; 50-265/81-04-03)

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The inspector observed apparent breaches in the three

hour rated fire barrier separating the Unit I and 2

Cable Tunnels from the Auxiliary Electric Equipment

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Room and the Turbine Building 595' level. These

breaches were various unrated personnel hatches for

the tunnels that were open and unsupervised and an

equipment penetration, covered by unrated metal floor

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plates which had been partially removed.

During the inspection, the inspector expressed concern

that the fire barrier may be degraded by these penetra-

tions. A determination of the adequacy of this barrier

will be made after more information is obtained.

(b) The inspector expressed the following concerns to the li-

censee either during the inspection or at the exit interview:

1.

The post indicator isolation valve on the main floor

in the Turbine Building for the hose and standpipe

stations servicing that area was not supervised

electronically 3r with tamper indicating seals.

2.

The emergency lighting battery inspections had not

been completed in 1980. The 1981 inspection was

in progress during the inspection and appeared to

be nearing satisfactory completion.

3.

Fire Protection and Prevention Administrative Controls

a.

Emergency Response Procedures

The inspector examined the licensee's fire emergency response

procedures and fire fighting strategies. The procedures and

strategies were reviewed using the requirements contained in

the license and FPSER with supporting licensee transmittals and

the NRC guidance document, " Nuclear Plant Fire Protection Func-

tional Responsibilities, Administrative Controls, and Quality-

Assurance."

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(1) Areas of Inspection

(a) Procedures

Number

Title

QEP 340-5

Station Fire Fighting

>

QAP 1170-3

Fires

(b) Records

Number

Title

Date

Form 86-9963

Reports of Fires

1980

QEP 340-S1

Fire Drill

1980

Worksheets

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(2) Findings

No apparent items of noncompliance were identified in this area.

(3) Discussion

(a) Unresolved Item (50-254/81-04-04; 50-265/81-04-04)

Amendment No. 52 issued July 27, 1979 to License No.

DPR-29 and Amendment No. 49 issued July 27, 1979 to

License No. DPR-30 states:

"The licensee is required to implement the

administrative controls identified in Section 6

of the SE.

The administrative controls shall be

in effect immediately .

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Section 6.0 of the FPSER states:

"Our review is based on this information [ letters

from the licensee dated April 24, 1978, July 27,

1978 and November 30,1970] and our understanding

that the licensee meets or will meet the specific

guidance found in " Nuclear Plant Fire Protection

Functional Responsibilities, Administrative Controls,

and Quality Assurance."

Paragraph d of Attachment No. S to " Nuclear Plant Fire

Protection Functional Responsibilities, Administrative

Controls and Quality Assurance" describes the minimum

subjects to be included in the fire fighting strategies

established for all safety related areas and areas pre-

senting a hazard to safety related equipment.

Paragraph g of the same attachment identifies the sub-

jects to be included in procedures for coordinating fire

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fighting activities involving offsite fire departments.

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Section 6.5 of the FPSER concerning fire fighting pro-

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cedures states:

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"The licensee has provided an adequate description

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of its current fire fighting procedures, those under

development and those planned to be. developed in the

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near future. Fire fighting procedures / plans are

established to cover such items as .

. coordination

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of fire fighting activities with offsite fire depart-

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ments, strategies for fighting fires in all safety

related areas and areas presenting hazard to safety

related equipment."

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Contrary to the above, the licensee has not developed

and implemented fire fighting strategies and procedures

for coordinating fire fighting activities involving off-

site fire departments.

The licensee takes issue with this position on the basis

of two sets of handwritten notes from an exit interview

at the conclusion of the NRR fire protection review team

site visit on August 24, 1978. These notes indicate that

the proposed licensee program as it is presently imple-

mented was acceptable.

This issue has been forwarded to IE Headquarters for

review and resolution.

(b) During the inspection, the inspector discussed with the

licensee various merits of the different approaches to

developing and utilizing fire strategies or pre-plans

and provided contacts with other licensees who have

developed strategies. The licensee indicated that he

would consider these recommendations.

Also, after reviewing the fire reports from 1980, the

inspector expressed concern to the licensee that the

contractor training in fire emergency response did not

appear to be effective. On one occasion, a contractor

did not report a fire to the control room, resulting in

the fire siren not being sounded. This caused some

confusion in the fire fighting response. The licensee

acknowledged this concern.

b.

Ignition Source Controls

The inspector examined the licensee's program for controlling

ignition sources. These administrative controls were reviewed

using Ute requirements contained in the license and FPSER with

support:.ng licensee transmittals and the NRC guidance document

" Nuclear Plant Fire Protection Functional Responsibilities,

Administrative Controls, and Quality Assurance."

(1) Areas of Inspection

(a) Procedures

Number

Title

QMP 100-3

Fire Prevention for Welding and Cutting

QAP 200-13

Station Housekeeping

(b) Records

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Number

Title

Date

QMP 100-S1

Welding and Cutting Permit

12/80

Form 86-9963

Reports of Fires

1980

(c) The inspector toured the plant on two occasions to

observe the implementation of the licensee's ignition

source controls. The following areas were toured:

Unit 1 Reactor Building

Unit 2 Reactor Building

Turbine Building

(2) Findings

Noncompliance (50-254/81-04-05; 50-265/81-04-05)

Technical Specification 6.2.A.11 states:

" Detailed written procedures .

. shall be prepared

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. and adhered to .

fire protection program

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implementation."

Maintenance Procedure QMP 100-3, Fire Prevention for Welding

and Cutting, paragraph F.1.a states:

" Areas where .

. welding .

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and all accumulation of trash, rags, etc. shall be

removed."

Paragraph F.1.b states:

"All . . . cable in trays .

. subject to damage or

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ignition .

. shall be covered with suitable noncom-

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bustible materials."

Parr. "ph F.3.a states:

"One or more individuals in each work area shall be

designated to watch for potential-fire or smoldering.

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Contrary to the above, during a plant tour the inspector

observed a contractor welder in the Unit 2 Cable Tunnel

performing welding operations above safety related cabling

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without a fire watch in the immediate area. Trays of safety

related cabling were not covered with suitable noncombustible

materials and were being exposed to potential damage or

ignition.

During another plant tour, the inspector observed a contractor

welder on the 643' level of the Unit 2 Reactor Building welding

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within fifteen feet of four bags of flammable resins. At the

time of the observation, the welders fire watch was forty feet

away performing grinding operations.

In review of the ten fire reports from 1980, the inspector

noted that four of these fires were caused by welding or

torch cutting operations where the workers had not followed

the procedures for performing their work. None of these

fires resulted in major damage.

Noncompliance (50-254/81-04-06; 50-265/81-04-06)

Technical Specification 6.2.B states:

" Radiation control procedures shall be maintained .

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and adhered to."

~ Radiation Protection Procedure QRP 100-1, Radiation Control

Standards, paragraph 15.C.6.'e states:

"Do not eat, smoke, drink, or chew in controlled

areas."

The licensee has defined the Unit I and Unit II cable tunnels

as controlled areas.

Contrary to the above, the inspector observed many cigarette

butts scattered throught the Unit I and Unit 2 cable tunnels

and an empty beer can in the Unit I cable tunnel.

(3) Discussion

The inspector discussed ignition source control problems

with the licensee during the inspection. The inspector

suggested a possible method of upgrading contractor aware-

ness of plant ignition control procedures by expanding the

hot work permit sheet to include specific requirements that

the supervisor, worker or fire watch would have to read and

initial. The licensee indicated that he would consider

this recommendation.

c.

Combustible Materials Controls

The inspector examined the licensee's program for controlling

combustible materials and transient fire loads. The program

was reviewed using the requirements contained in the licensee

and FPSER with supporting licensee transmittals and the NRC

guidance document " Nuclear Plant Fire Protection Functional

Responsibilities, Admir.istrative Contiols, and Quality Assurance."

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(1) Areas of. Inspection

(a) Procedures

Number

Title

QAP 200-13

Station Housekeeping Organization

QAP 600-8

. Storage of Chemicals

QMP 100-3

Fire Prevention for Welding and Cutting

QAP 600-9

Storage of Resins

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(b) Plant Tours

The inspector examined the plant combustible control'

practices during two plant tours of the following

areas:

Screenhouse

Unit 1 Reactor Building

Unit 2 Reactor Building

Turbine Building

(2) Findings-

Noncompliance (50-254/81-04-07; 50-265/81-04-07)

Technical Specification 6.2.A.11 states:

" Detailed written procedures .

. shall be prepared . . .

.

and adhered to . . . fire protection program implementation."

Administrative Procedure QAP 200-13, Station Housekeeping

Organization, paragraph C.3 states:

"The working department or support group is responsible

for returning all areas affected by their work to normal

acceptable cleanliness when work is finished. This

includes:

a.

Removing all combustible material and debris from

the work area.

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b.

Returning excess material and equipment to the

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normal storage area.

c.

Removing all tools, equipment and material from

the area when the job is complete."

Paragraph C.5 states:

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"The Stationmen do routine housekeeping to assure that

normal acceptable cleanliness is maintained. This in-

cludes timely removal and emptying of trash collection

containers and cleaning of floors. The Stationmen clean

areas as assigned and requested by Station Management to

maintain adequate cleanliness.

Where material or equipment

exists that cannot be handled or controlled by other de-

partments,' the Maintenance Department or any other depart-

- ment may be called on for support."

Paragraph C.6 states:

"The foreman of the stationmen performs periodic

inspections of the plant to ensure that cleaning is

being performed sufficiently to prevent the following:

a.

Accumulation of debris and combustible material in

the plant.

(1) The Fire Marshall shall be notified if there

is an increase in the probability of a fire

in a given area.

b.

Development of unsafe conditions due to lack of

cleanliness such as oil spills.

c.

Accumulation of tools, material or equipment in

non-storag areas."

Contrary to the above, the inspector toured safety related

areas and observed unacceptable housekeeping practices which

have the potential to degrade the safe operation of the plant.

Unacceptable accumulations of combustible materials were

observed in the following areas:

Unit 2 Spent Fuel Pool Cooling Equipment Area

Unit 2 Reactor Building 643' Level Sample Station Area

Unit 2 Cable Tunnel

Unit 2 Control Rod Drive Hydraulic Equipment Area

HPCI 250V DC Bus 2A Area

Auto Blowdown Panel 2202-32 Area

1/2 Diesel Generator Room

Turbine Building Main Floor 4kV Switchgear Area

Auxiliary Electric Equipment Room

Unit 1 Cable Tunnel

(3) Discussion

The inspector discussed housekeeping problems with the

licensee who indicated that he would consider implementing

a weekly tour of all picat areas by plant personnel to

control accumulations of combustible materials.

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d.

Fire Protection Audits and Inspections

The inspector examined the licensee's program for auditing and

inspecting the fire p*otection and prevention program through

the quality assurance organization and off-site organizations.

The program was reviewed using the requirements in the plant

technical specifications.

(1) Areas of Inspection

Quality Assurance Audit Report - April, 1980-

Training / Qualifications Checklist

Fire Protection Checklist

Fire Protection Consultant Inspection Report - November, 1979

Fire Protection Consultant Inspection - November, 1980

(2) Findings

No apparent items of noncompliance were identified in this

area.

4.

Fire Protection and Prevention Training

a.

General Employee and Contractor Training

The inspector examined the licensee's fire protection and pre-

vention training program for general employees and contractors.

The training was reviewed using the guidelines contained in the

Commonwealth Edison Company Nuclear Fire Protection Program.

(1) Areas of Inspection

General Employee Training Program Lesson Plans

General Employee and Contractor Training Records

(2) Findings

No apparent items of noncompliance or deviations were

identified in this area.

(3) Discussion

The fire protection and prevention topics discussed in the

general employee and contractor training include classes

of fires, hot work permits, housekeeping, and the fire

emergency siren recognition and response.

b.

Fire Brigade Training

The inspector examined the licensee's program for fire brigade

training including initial classroom training and retraining,

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fire fighting practice sessions, fire drills, and actual fire

fighting. The training program was reviewed using the require-

ments contained in the. license and FPSER with supporting licensee

- transmittals, the NRC guidance document " Nuclear Plant Fire Pro-

tection Functional Responsibilities, Adminstrative Controls, and

,

Quality Assurance" and the Commonwealth Edison Company Nuclear

Fire Protection Program.

(1) Areas of laspection

Fire Brigade Classroom Training Lesson Plans

Fire Brigade Initial Training Records

Fire Brigade Requalification Training Records

Fire Fighting Practice Session Records

Fire Drill Worksheets

Fire Report Forms

(2) Findings

No apparent items of noncompliance were identified in this

area.

(3) Discussion

(a) Unresolved Item (50-254/81-04-08; 50-265/81-04-08)

Amendment No. 52 issue *d July 27, 1979 to License No.

DPR-29 and Amendment No. 49 issued July 27, 1979 to

License No. DPR-30 states:

"The licensee is required to implement the admin-

istrative centrols identified in Section 6 of the

SE.

The administrative controls shall be in effect

immediately . . ."

Section 6.0 of the FPSER states:

"Our reeiew is based on this information [ letters-

from the licensee dated April 24, 1978, July 27,

1978, and November 30, 1978] and our understanding

that the licensee meets or will meet the specific

guidance found in " Nuclear Plant Fire Protection

Functional Responsibilities, Administrative Controls,

and Quality Assurance.

.

Section 6.2 of the FPSER" states:

"The Fire Brigade Training Program consists of .

. .

fire drills. The Fire Brigade Training Program

includes

. . periodic fire drills, and critiques

.

to assess brigade effectiveness."

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Paragraph 3.0.e of Attachment No. 2 to " Nuclear Plant

Fire Protection Functional Responsibilities, Adminis-

trative Controls and Quality Assurance" concerning

fire drills states:

"The drills should be performed at regular inter-

vals but not to exceed three months for each fire

brigade. At least one drill per year should be

performed on a "back shif t" for each fire brigade.

A sufficient number of these drills, not less than

one for each fire brigade per year, shall be un-

announced, to determine the fire readiness of the

plant fire brigade leader, brigade, fire protection

systems and equipment."

The NRC fire drill position is further clarified in

10 CFR 50 Appendix R, effective February 19, 1981,

paragraph III.I.3.b. which states"

"Srills shall be performed at regular intervals not

to exceed three months for each shift fire brigade.

Each fire brigade member should part icipate in each

drill, but must participata in two drills per year."

Contrary to the above, the licensee conducted only

six fire drills in 1980 and had five fires with fire

brigade response. After compiling the attendance

records, the inspector identified that seventy-six

percent of the fire brigade members had attended fewer

1

than the minimum acceptable number of fire drills

according te 10 CFR 50 Appendix R (see table below).

These attendance figures exclude two actual fires where

specific attendance was not recorded; only the number

of responding brigade members was recorded.

PERCENT OF FIRE BRIGADE + ATTENDING

WORKER CLASSIFICATION ZERO DRILLS * ONE DRILL * TWO DRILLS THREE DRILLS

>

Equipment Attendants

23% (7)

52% (16)

19% (6)

6% (2)

Rad / Chem Technicians

68% (15)

27% (6)

5% (1)

0% (0)

Rad Waste Foremen

0% (0)

20% (1)

80%

-)

0% (0)

Shift Foremen

38% (3)

25% (2)

37% (3)

0% (0)

• Workers attending fewer ~than two fire drills per year are not considered

qualified for fulfilling the minimum fire brigade staffing requirements

under the new fire protection rule, 10 CFR 50 Appendix R.

+The numbers in parenthesis indicate the actual number of fire fighters in

each category.

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The licensee takes issue with this position on the

basis of two sets of handwritten notes from an exit'

interview at the conclusion of the NRR fire protection

review team site visit on August 24, 1978. These notes

indicate that the proposed licensee program as it is

presently implemented was acceptable.

This issue has been forwarded to IE Headouarters for

review end resolution.

(b) The inspector reviewed.the training lesson' plans for

fire brigade initial training and retraining. These

classroom training lesson plans appear acceptable.

The inspector reviewed the fire brigade training

records for approximately twenty percent of the fire

brigade leaders and members including employees from

the following job categories:

Shift Foreman (2 of 8)

Radwaste Foreman (1 of 5)

Equipment Attendant (7 of 31)

Rad / Chem Technician (4 of 22).

Of those records reviewed, all persons had received

the initial fire brigade training and at least. quarterly

retraining in 1980. All persons had attended at least

one hands-on fire fighting practice session in 1980 with

10 of 14 attending two practice sessions.

5.

Exit Interview

The inspector met with the licensee representatives (denoted in

paragraph 1) at the conclusion of the inspection on' February 27,

1981. The purpose and scope of the inspection was summarized

and the findings were discussed.

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