ML20003J110
| 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: |
| 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
Text
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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
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
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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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1.
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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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 . . .
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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
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
(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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