ML20154B737

Safety Insp Repts 50-373/86-04 & 50-374/86-04 on 860113-27. Violation Noted:Failure to Install Fire Detection & Alarm Sys Per Governing Code Requirements

ML20154B737
Person / Time
Site:	LaSalle
Issue date:	02/27/1986
From:	Falevitz Z, Guldemand W, Guldemond W, Holmes J, Ramsey C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20154B698	List: ML20154B694 ML20154B711 ML20154B737
References
50-373-86-04, 50-373-86-4, 50-374-86-04, 50-374-86-4, NUDOCS 8603040383
Download: ML20154B737 (19)

See also: IR 05000373/1986004

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Reports No. 50-373/86004(ORS);50-374/86004(DRS)

4 Docket Nos. 50-373; 50-374 Licenses No. NPF-11; NPF-18

. Licensee: Conzonwealth Edison Company

P.O. Box 767

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Chicago IL 60690

Facility Name

LaSalle

Inspection At: LaSalle Nuclear Power Station, Marseilles, Illinois

Inspection Conducted: Jan ry 13-27, 6

Inspectors: .

<# 7

Date

C. Ramsey ENh Date

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/

. Holmes '

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'Date

I. N N~

Z. Falevitz 2/27Mt

.Date

/

Approved By: . ul ' n't , #/27M

Operational Programs Section Da te

Inspection Summary

Inspection on January 13-27, 1986 (Report No. 50-373/86004(DRS)1

50-374/86004(DRS))

Areas Inspected: Special announced safety inspection conducted to close out

previous open items, to assess licensee conformance to routine fire protection

program requirements and review allegations concerning fire brigade training.

The inspection involved 156 inspector-hours by four NRC inspectors, including

zero inspector-hours onsite during off-shifts.

Results: Of three areas inspected, no violations or deviations were

identified in two areas. One violation was identified in the remaining area

(Failure to install fire detection and alarm systems in accordance with

governing code requirements - Paragraph 4.a.).

8603040383 860228

$DR ADOCK 05000373 -

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DETAILS

1. Persons Contacted

• G. Diederich, Station Manager

• R. Bishop, Services Superintendent

l C. Allen, Nuclear Licensing Administrator

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R. Rybak, Station Nuclear Engineering Department

C. Barnes, Station Nuclear Engineering Department

• D. Roberts, Fire Protection Engineer

i *T. Gray, Fire Protection Engineer

l *T. Novotney, Fire Brigade Instructor

• D. Trager, Station Fire Marshal

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l *J. Kodrick, Maintenance Staff Engineer

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• B. Collins, Assistant Fire Marshal

• P. Manning, Technical Staff Supervisor

• A. Settles, Assistant Technical Staff Supervisor

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• T. Hammerich, Assistant Technical Staff Supervisor

• M. Jeisy, QA Supervisor

• T. Gallagher, QA

• J. Kocek, Technical Staff

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W. Sheldon, Assistant Superintendent, Maintenance

D. Berkman, Assistant Superintendent, Technical Services

M. Shiable, Training

G. Roberts, Technical Staff

• G. Morey, Electrical Maintenance Foreman

• T. Meyer, Braidwood Station Fire Marshal

• P. Hart, QA

• R. Crawford, Training Supervisor

j U.S. NRC

• S. Stasek, Resident Inspector

• R. Koprivra, Resident Inspector

• Denotes those in attendance at the exit meeting of January 27, 1986.

2. Licensee _ Ac_tions on Previous Inspection Findings

(Closed) Violations (373/82-54-03; 374/82-22-03): These violations

documented inadequacies in the licensee's cable tray cleanliness program

as evidenced by the discovery of miscellaneous debris in cable trays. '

The licensee has implemented the following procedures addressing plant

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cleanliness including cable trays: LES-GM-101, " Cleaning Cable Tray and

Electrical Panels" and LAP-900-15, " Housekeeping Practices." These

procedures provide explicit directions on how to clean cable trays and

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require periodic cable tray inspections.

(Closed) Violations (373/82-54-01; 374/82-22-01): These violations

e consisted of three parts. The first two parts dealing with a lack of

acceptance criteria for fire seals and failure to prepare Nonconformance

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Reports for deficient seals, were closed in IE Inspection Reports

No. 50-373/83-44 and No. 50-374/83-48. The third part dealt with a

failure on the part of the licensee to ensure procedures were in place to

specify proper mix control of Fire Code CT Gypsum. The inspector reviewed

Transco procedures entitled, "Special Process - Fire Code CT Gypsum," and

" Fire Code CT Gypsum Cement Application and Installation Procedures."

These procedures specify explicit mix proportions for various

' applications.

(Closed) Unresolved Items (373/84-33-05; 374/84-40-04): These items

documented concerns over the adequacy of procedural controls placed on

the use of ignition sources. The inspector reviewed Procedure LAP-900-10,

" Fire Prevention Procedure for Welding and Cutting," and LAP-900-22, "Use

of Heat Generating Equipment and Heat Sources." LAP-900-10 provides the

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controls necessary to ensure proper control is exercised during and after

welding, grinding, cutting, and open flame operations. LAP-900-22

provides the controls necessary to ensure proper control is exercised

during the use of heat generation or heat source equipment capable of

generating a temperature high enough to cause ignition of combustible

material in the vicinity of the equipment. It was noted that the

procedures overlap in establishing controls over the use of propane

torches. While LAP-900-22 speaks explicitly to use of propane torches,

it does not require the use of the welding and cutting permit system.

LAP-900-10 does not speak explicitly to propane torches but does cover

open flame work. As propane torches de produce an open flame, they fall

under LAP-900-10. The licensee is encouraged to clarify their procedures

in this area.

(0 pen) Unresolved Item (373/82054; 374/82022-05): Floor penetration

seals in the control room exceed the dimensions of the fire stop designs

actually tested.

In response to this issue, there were meetings held at NRC headquarters

with the Office of Nuclear Reactor Regulation (NRR), Region III (RIII),

and licensee personnel in the fall of 1983. Subsequent to this, the

licensee made several submittals to NRR of fire test data to support

penetration fire seal designs. NRR evaluated the licensee's submittals

and made determinations of acceptability that were not published.

It is not clear which tests were reviewed and accepted by NRR as being

representative of particular penetration fire seal installations. The

inspector was unable to determine if any of the tests submitted by the

licensee were representative of the control room penetration fire seal

configuration. Therefore this item is being referred to NRR for

resolution.

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(0 pen) Unresolved Item (373/83044-01): 10 CFR 50, Appendix R,

Sections III.G.3 and III.L require that if the licensee elects to establish

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alternative safe shutdown capability, that provisions for direct readings

of process variables necessary to perform and control the reactor shutdown

function shall be provided. Current NRR supplied guidance requires the

i following instrumentation be available for safe shutdown of BWR plants:

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a. Reactor water level and pressure

b. Suppression pool level and temperature, and

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c. Diagnostic instrume.tation for shutdown systems,

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i The licensee has. supplied instrumentation to monitor reactor water level

4 and pressure, suppression pool level and temperature, RHR service water

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flow, RHR flow, and RCIC flow in both the control room and at the remote

shutdown panel. The licensee previously stated that the only instrumenta-

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tion not reviewed for fire damage were suppression pool level and

temperature.

The licensee is providing instrumentation for Unit'l suppression pool

i level and temperature during the current outage which will prevent a

single fire from damaging cable for Remote Shutdown Panel indications and

the Control Room indications which is identical to that installed in

! Unit 2. This item will remain open pending completion and inspection of ,

J the modifications to this instrunentation for both units. ,

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4 (0 pen) Open Items (373/83-44-03h; 374/83-48-24): The licensee failed to

, establish adequate quality assurance acceptance / rejection criteria as

required by NFPA codes and standards for several surveillance tests.

. The inspector reviewed the following surveillance procedures for quality

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assurance acceptance / rejection criteria as required by NFPA codes and

i standards:

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a. LES FP03, " Hydrogen Seal Oil Unit Deluge Initiation Circuit

Functional Test."

b. LOS FPA1, " Fire Protection Flow Path Valve Cycling Test."

c. LOS FPA2, " Fire Protection System Function Test."

d. LOS FPA3, " Fire Protection Sprinkler and Deluge System. Drain Flow i

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and Cycling Test."

e. LMS FP06, " Fire Protection hose Station Valve Operability and Flow

Verification."

No deviations were identified except those noted below

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Procedure LOS FPA2 entitled " Fire Protection Functional Test" does not

j- incorporate NFPA requirements. The procedure should outline the.

necessary steps to assure that the fire pumps are tested in accordance

, with applicable HFPA Code requirements-and design documents as-well as-

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satisfy Technical Specification Surveillances.

Procedure LOS FPA3 " Fire Protection Sprinkler and Deluge System Drain

Flow and Cycling Test" outlines the steps necessary to:

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a. Cycle the Sprinkler Alarm Check Valves

b. Cycle the Sprinkler and Deluge Inlet Stop Valves and verify

that the associated Tamper alarms are Operational

c. Conduct Drain Flow Test on Sprinkler Systems

d. Conduct Full Flow test on Deluge System.

For sprinkler systems, the licensee conducts two-inch drain tests but does

not include an inspector's test, which is required by NFPA-13A to be

conducted quarterly.

In this procedure, the deluge system is tested by conducting a drain' test.

This is one of several tests that may be conducted on a deluge system. '

The licensee is requested to contact the manufacturer and develop a

procedure that will be adequately address testing of the deluge systems.

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3. Followup cn Allegatiens

The inspectors performed followup activities relative to an a*1egation

received by the NRC frcm an individual outside of the licensee's

organizaticn pertaining to the-adequacy of training provided to fire

brigade members and qualifications of certain staff members responsible

for the fire protection program at LaSalle County Station. Results are as

shown for each subject of the allegation..

Allegation RIII-85-A-0205

a. (0 pen) Training provided to members of the LaSalle fire brigade was

not adequate to permit the brigade members to perform their duties

as firefighters. The alleger identified a fire drill in one of the

ECCS rooms which apparently was not handled well by the station fire -

brigade.

The inspectors examined fire brigade drill critique records and

records of training sessions held during the years 1984 and 1985-

to detennine the quality of these activities. Thornugh interviews

were held with selected fire brigade members, the licensee's training

staff, the station fire marshal and cognizant-licensee pe .,nnel.

The following are the results of these activities:

(1) Fire Brigade Drill Critiqu_es

Fire brigade drill critiques were incomplete in some instances

because they did not contain adequate assessment of the drills.

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For example, in an August 10,.1984-drill that simulated a 4160V'

switchgear fire, the drill critique did not assess the fire  ;

brigade leader's ability to determine the need for offsite fire l

department assistance. -The critique did not mention whether any

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decision was made in this regard.

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None of the drill critiques examined made any assessment of

individual fire brigade member performances during drills (i.e.,

physical, mental and emotional fitness to perform the required

duties).

(2) Fire Brigade Drills

It appears that the drills were conducted at regular intervals

and each brigade member received a minimum of two drills per

year, including one drill per year that consisted of the use of

a self-contained breathing apparatus in a artificially smoke

filled environment within the smoke house. -The nature of the ,

drills conducted was diversified and contained a variety of

simulated fire conditions such as internal structural fires

involving electrical equipment, internal structural fires

involving oil storage tanks, external fires involving flammable

liquid spills, and fires involving motor vehicles.

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All of the drills conducted appeared to rely on the use of

portable fire extinguishers as the primary method of fire

extinguishment. Fire hose stations appear to have been used in

the drill simulaticns, but, according to the licensee's staff,

fire brigade trainir.g has been largely focused on the use of

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portable fire extinguishers.

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(3) Hands on Practice - Use of Fire Hose Stations

The use of fire hose stations on practice grounds or on practice

fires under actual fire conditions is not required of individual

participants to become a member of the fire brigade. The

licensee's staff indicated that sometimes line fire hose

practice was conducted in the summer months on practice grounds,

but this activity was difficult to continue due to objections

raised by station operations because of recurring problems with

the station fire pumps. All fire brigade members have not been

trained in the use of the high pressure hose streams used at i

LaSalle while fighting internal structure fires.

(4) Hands on Practice - Use of Portable Fire Extinguishers

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According to the licensee, live fire extinguishment of actual

fires with portable fire extinguishers is provided to all

station employees, but no documentation was provided to verify

that all fire brigade members received this training prior to-

becoming a fire brigade member.

(5) Smoke House Training Facility

According to the licensee, one drill per year includes a

challenge to fire brigade members within the licensee's smoke

house training facility. Artificial smoke is introduced into

the smoke house and fire brigade members dressed in complete

turn-out gear and self-contained breathing apparatus have to

find their way through the smoke-filled area.

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The smoke house is a concrete and steel structure approximately

15 feet by 50 feet with a 20 foot ceiling. Wooden props are

erected in part of the building area that simulate obstacles in

the form of walls, three steps, and crawl-through spaces.

While the licensee's smoke house facility provides some

challenge to fire brigade members, this challenge is not

equivalent to the challenges or the quality of training that is

provided by State Certified Firemanship Training Facilities

such as those required by NFPA Standard No. 27 and Chapter XVII,

of Federal OSHA Standard No. 1910.156 (Subpart L).

(6) Fire Brigade Classroom Instruc Ron Trai_nin.g

The inspector's review of the licensee's fire brigade classroom

training lesson plans and interviews with selected fire brigade

members indicate a broad range of firefighting subjects are

covered in classroom lectures; however, no objective measurement

is made of individual brigade member's comprehension of this

training because written or oral qualifying examinations are not

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administered on any of the subject matter at any time.

Furthermore, an initial 20 hour2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> classrocm training session

is all that is required for individuals to qualify as a fire

brigade member. Based on the inspector's review and interviews

with fire brigade members, this training does not contain the

quality and depth of training that is intended by the

requirements of Chapter 4 of NFPA 27, NRC guitelines or Federal

OSHA requirements.

(7) Selection of Fire Brigade Members

The licensee's employment policy is that a particular class

of employee (Operators classed as "B" men) must be members

of the fire brigade. Though not stated in a job description

(according to the licensee), this is a condition of employment.

During the inspector's interview with fire brigade members', some

brigade members expressed discontent with this policy because of

a fear of firefighting; personnel impositions placed on them

and/or improper training and experience in the hazards involved

in firefighting at the facility.

While other fire brigade members interviewed expressed

enthusiasm and genuine interest in the fire brigade, the

licensee's employment policy is not consistent with the

requirements of Section 3-2.3.3 of NFPA Standard No. 27,

which states in part, "only persons meeting physical,

mental and emotional requirements should be considered

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eligible to serve on the fire brigade." The licensee has

not established mental and emotional requirements for fire

brigade members. l

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Based on the NRC's direct _ investigation, review of pertinent fire

brigade records, and brigade training programs, and interviews with

cognizant licensee personnel, this allegation was substantiated and

the following s:2cific conclusions were reached:

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(1) Fire brigade drill critiques did not contain adequate

assessments of individual fire brigade member performances

during drills.

(2) Fire brigade drills did not include practice sessions using hose

lines in actual fire extinguishment during continuing practice

sessions.

(3) Hands on practice using fire hose stations was inadequate -

because individual brigade members are not required to be

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trained in the use of hose lines prior to becoming a brigade i

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member.

(4) Fire brigade members are not required to use hose lines to

extinguish actual fires prior to becoming a fire brigade member

and this is not a stated requirement of the licensee's fire

brigade training program.

(5) No documentation is available to verify that fire brigade

members have been properly trained in the use of high pressure

hese streams that exist in the plant for internal structural

firefighting.

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) (6) High pressure hose lines that exist in the plant deviate from

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the licensee's commitment to NFPA Standard No. 14.

(7) Fire brigade yard hose line practice without fire extinguishment

for the fire brigade was discontinued for the fire brigade

because of operations problems with the station fire pumps.

(8) The licensee could not verify that individual fire brigade

members received hands on practice using portable fire

extinguishers in actual fire extinguishment prior to their

becoming a fire brigade member. This is not a stated l

requirement of the licensee's fire brigade training program.

(9) The licensee's smoke house training facility does not provide

equivalent training experience for internal structural

firefighting to that which is provided by State Certified

Firemanship Training Facilities that are referenced in NFPA

Standard No. 27.

(10) Fire brigade classroom instruction training was inadequate

because it did not require qualifying examinations at any time

for any subject matter.

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(11) The licensee's employment policy dictates that certain employees

must become members of the fire brigade. No criteria has been

establish to assure that these employees are suitable to

perform firefighting duties as required by the licensee's

comitment to NFPA Standard No. 27.

These specific conclusions indicate that the licensee has not

adopted a performance-based training approach for the fire brigade.

That approach would have identified these and other weaknesses which

may exist in the fire brigade training program. Licensee management

was encouraged to adept a performance-based training progran for the

fire brigade.

b. (0 pen) Training Departnent personnel were not qualified technically

to give fire brigade training.

Direct investigation of the licensee's training staff and interviews

with training instructors responsible for fire brigade training

revealed that the fire brigade training instructor has had some fire

protection related classes over a five year period. The assistant

fire brigade training instructors have had a number of one to three

day firefighting courses over a two year period and one seven day

firefighting course at Great Lake Naval Training Center in 1973.

The fire brigade training instructor does not claim any firefighting

or fire prevention and control experience other than his volunteer

firefighting experience and certification as a Firefighter II

Instructor through the University of Illinois Extension. The

assistant fire brigade instructor claims firefighting experience as

an officer in charge of a U.S. Naval Damage Control and Firefighting

Team from 1977 to 1979; U.S. Naval Damage Control and Firefighting

Team tember from 1973 to 1979, and active member of the Mazon,

Illinois volunteer fire department from 1982 to the present.

While NRC Fire Protection program guidance docurrents do not specify

technical qualifications for fire brigade training instructors, the

licensee's FSAR Comitment to NRC Branch Technical Position 9.5.1

commits the licensee to comply with the requirements of NFPA

Standard No. 27 for fire brigade training. Sections 4-2.1 and 4-2.2

of NFPA Standard No. 27 require that fire brigade training be

conducted and supervised by a state certified fire service instructor,

public fire department, or qualified private consultant. Members of

the fire brigade are required to be afforded opportunity to improve

their knowledge of firefighting and fire prevention through

attendance at outside meetings and special hazard training classes.

The fire brigade training instructore aining and experience in

firefighting and fire prevention doe r t appear to meet the j

requirements of NFPA Standard No. 27, and according to interviews I

with cognizant individuals of the licensee's staff, all fire brigade '

members are not afforded the opportunity to'attsnd outside training

classes by qualified instructors on the special hazards of internal

structural firefighting at nuclear power plants.

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Based on the NRC's investigation and review of the fire brigade

training instructors' qualifications and interviews with cognizant

licensee personnel, this allegation was substantiated because of

the fire brigade training instructors' minimum qualifications, and

because the outside special hazards training that satisfies the

requirements of NFPA Standard No. 27 is not being provided to fire

brigade members. Again, it is felt that had the licensee applied

the principles of performance-based training to this functional

area, this problem would have been avoided,

c. (0 pen) Training department and station management have not supported

fire brigade training.

Interviews with cognizant licensee personnel revealed that the

licensee's training department and station management have been

reluctant to provide outside fire brigade training and have

discontinued fire brigade live hose stream practice sessions because

of operations problems concerning the station fire pumps. It appears

that the licensee considered fire brigade classroom sessions with no

examinations adequate for initial fire brigade training. At some

point in an employee's tenure, portable fire extinguisher training is

provided for all general employees. This is the extinguisher

training that is relied upon for fire brigade members to receive

initial hands-on practice with portable fire extinguishers. For

continuing training, the licensee considered each brigade member's

attendance at a minimum two fire drills per year, with one drill

consisting of the smoke house challenge, to be adequate fire brigade

training.

Based on the NRC's investigation and review of fire brigade training

records and interviews with cognizant licensee personnel this

allegation was substantiated. The review of selected fire brigade

member training records revealed that fire brigade members were not

receiving outside special hazards training in internal structural

firefighting. The licensee's fire brigade training staff and station

management personnel stated it had been their position that the

onsite fire brigade training program was adequate; therefore it was

not necessary to provide outside fire brigade special hazards

training. Furthermore, the licensee's training and management staff

acknowledged the discontinuation of fire brigade training in the use

of line hose streams due to operations problems with the station

fire pumps.

d. (0 pen) The station fire marshal wat not qualified technically.

Currently, the NRC has not specified any formal qualification

requirements for the position of fire marshal; however, based on the

NRC's investigation, review cf the staticn fire marshal's

qualifications, and interviews with cognizant licensee personnel, the

inspectors concluded that the station fire marshal has only a minimum

of training in firefighting. He has no fire prevention, fire

technology or fire protection engineering formal training or

experience, and he has been the station fire marshal for four months.

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This is viewed as a serious disadvantage to the individual filling

this position and to fire protection program implementation because

i the responsibilities of the station fire marshal entail duties that

require a broad range of fundamental and_ in-depth technical knowledge

and expertise in fire science, fire engineering, firefighting, fire

prevention,'and regulatory and code interpretation.

Within the licensee's organizational structwe, the station fire

marshal is assigned responsibilities that include establishing

authority and assigning responsibilities for fire protection pr.ogram

implementation, recommending program improvements to management,

establishing firefighting strategy and its impact on plant .

i operations, inspecting the plant for control of fire hazards,

developing procedures and reviewing surveillance test results to

determine operability of equipment, reviewing all fire prevention ,

i inspections, preplanning fire hazards and targeting problem areas,

recommending to management the purchase.of needed equipment, keeping

j! management infonted as to the condition of equipment and the status

of the fire brigade, monitoring welding and cutting activities,

performing fire investigations, and making fire reports.

Although NRC guidelines do not specify technical qualifications for

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individuals filling the position of station fire marshal, it is

Region III's position that this individual should have a_ thorough

knowledge of fire prevention and control methods that is supported

. by formal training and actual experience in fire protection, as well '

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as a thorough knowledge of the plant, prccedures, and regulatory and

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code requirements, or have such knowledge and experience imediately

" available in the form of an assigned staff while the necessary

knowledge and experience are gained.

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Based on the NRC's investigation and review of the station fire

marshal's qualifications, this allegation was substantiated.

The station fire marshal's limited training and experience in fire

protection serves as a potentially serious disadvantage to his

j position as well as the licensee's overall fire protection program

implementation.

e. (0 pen) Tests were not administered after fire' brigade training.

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l' The NRC's investigation of this allegation is discussed in

Paragraph 3.a of the report. Examinations are not administered on

any subject at any time during the licensee's fire brigade training

program.

Based on the NRC's investigation discussed in Paragraph 3.a of_the

report, this allegation was substantiated.

! In sumary, the NRC conducted a review of an allegation- received' relative

j to inadequacies-in fire brigade training and deficiencies in the

qualifications of ce'rtain personnel responsible for implementation of the

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licensee's fire protection program. As a result of-the review, it was-

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determined that, while no explicit regulatory requirements were violated,

the concerns expressed by the alleger possessed merit. Taken in

aggregate, the deficiencies identified during the review create the

potential that fire brigade effectiveness and fire protection program

implementation may be compromised. Further, it was the conclusion.of the

inspectors that the deficiencies identified resulted from a failure on

the part of the licensee to clearly establish their expectations of and

priorities for these aspects of the fire protection program and build

training and qualification requirements around those expectations and

priorities . Rather, it appeared to the inspectors that the licensee had

based training and qualification requirements on minimum regulatory

requirements and guidance.

The findings and conclusions resulting from the inspectors' review of the

allegation, including the . conclusions relative to the methodology and

basis for establit.hing training and qualification requirements for fire

protection personnel, were discussed with the licensee during the exit

interview on January 27, 1986. The licensee did not take exception to

any of the specific findings and proposed corrective actions responsive

to those findings. With respect to the more general conclusions relative

to expectations for fire protection personnel, their training, and their

qualifications, the licensee stated that Comonwealth Edison had recently

undertaken a reevaluation of these a M other issues on a corporate-wide

basis. This reevaluation, initiated as a result of internally and

NRC-identified issues at other Commonwealth Edison nuclear stations, is

scheduled for completion late in the second quarter of 1986, at which time

actions will be initiated to resolve the findings of the reevaluation.

This comprehensive approach to resolution of the identified deficiencies

is acceptable to Region III. The allegaticn which prompted the' review

documented above will remain open pending review of the results of the

licensee's reevaluation and inspection of implementation of the resulting

corrective actions. This is currently expected to occur in September

1986.

4. Implementation of Routine Fire _ Pr_o_t_ec_ tion _ Program _ Requirements

Facility operating License Nos. NPF-11 and NPF-18 require that the

license maintain in effect all provisions of the approved fire protection

program for LaSalle Station, Units 1 and 2. The inspectors assessed

selected areas of the licensee's fire protection program for compliance

with stated regulatory requirements. The results of these. assessments

are as follows:

a. Building Design-Fire Detection System Installation

Appendix A to NRC Branch Technical Position (BTP) 9.5-1, its

supplemental guidance, and Appendix R to 10 CFR 50 mcke up the

requirements for an approved fire protection plan that satisfies

Criterion 3 of Appendix A to 10 CFR 50. The licensee's FSAR response

to NRC Question No. 010.45 committed to installation of fire

detection systems installed in accordance with National Fire

Protection Association Standard No. 720. Based on this commitment,

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the NRC staff concluded in Section 9.5.1.4 of the-original. Safety

Evaluation Report (SER) that fire detection systems for both LaSalle

units were installed or would be installed in accordance with NFPA

Standard No. 720. No deviations from NFPA 72D requirements were

granted to the licensee in subsequent SER supplements one through six

by the NRC and none were identified to the NRC by the licensee prior

to this inspection.

Appendix A to BTP 9.5-1. requires that fire detection systems give

audible and visual alarms in the control room and a local audible

alarm that sounds at the location of the fire. A local alarm is

defined by NFPA 720 as an intermediate fire alarm or fire supervisory

control unit used to provide area' fire alarm or area fire supervisory

service. Sections 4-1 and 4-2.3 of NFPA 72D specify that signal

! notification requirements in a central. supervisory station and, if

l provided, signal notification for evacuation of occupants, or signals

l directing aid to the location of an emergency, comply with the

l provisions of NFPA Standard No. 72A in addition to the provision of

NFPA 72D.

Section 3-9.1 of NFPA-72D references Table 3-9.1 of NFPA 72D to

explain the performance of alarm initiating device circuits.

Table 3-9.1 allows users to identify minimum performance of present

and future fire alarm systems by determining the trouble and alarm

signals received at a central supervising station (control room) for

specified abnormal conditions. According to Table 3-9.1 of NFPA 720,

intermediate fire alarms (local alarms) or fire supervisory control

units (control room fire detection system annunciator) are required

to be supervised to give distinct trouble alarms in the control room

under specified abnormal conditions.

Section 2-4.1 cf NFPA 72A requires that all fire alams and process

monitoring alarm systems be electrically supervised so that the

occurrences of a single open or a single ground fault condition of

l installation wiring which prevents the required normal operation

'

of the system, or failure of its primary power supply source will

be indicated by a distinct trouble signal. This is graphically

displayed in Table 3-9.1 of NFPA 720. Furthermore, Section 2-7.1

of NFPA 72D requires that all interconnecting equipment, devices

and appliances to proprietary signaling systems be monitored for

integrity so that the occurrence of a single open or a single ground

trouble condition will be automatically signaled to and recorded in

the central supervising station within 200 seconds.

During the inspection on January 14, 1986, local alarms in the Unit I

reactor building were giving audible fire alarms simultaneously

as a result of a wire to wire short. No trouble alarm indication was

received in the control room because the local alarm circuits, which

! are manually initiated only from the control room, are not

electrically supervised in accordance with NFPA 720 and 72A

requirements. According to interviews with cognizant licensee

personnel, this was a recurring event that confused employees and

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diminished employee and fire brigade member confidence _ in the fire

alarm system to the extent that it is difficult for employees to

distinguish an actual fire alarm from a false alarm.

The inspector's investigation of the actuated alarms _resulted in the

determination that the local alarms were not electrically supervised

in the control room. Because of this lack of electrical supervision,_

control rocm operators were unable to pinpoint the location of the

actuated alarms and the manual reset button for the local alarm

circuits was inoperative; therefore, the alarms rang in the Unit 1

reactor building for approximately six hours while the inspectors

i were onsite until the licensee's staff de-energized the fault

'

that was causing the problem.

'

In addition, the licensee identified to the inspector, and the

inspector verified, that the control room visual alarm annunciator

circuit for the fire detection system was not electrically supervised..

A single open or a single ground fault condition in this circuit

• .

cculd cause the loss of all control room visual alarm annuciation ,

! for the fire detection system without any notification to control *

rocm operators of abnornal conditions in the circuit.

For the local fire alarm condition, the' licensee took exception

to NFPA 72D and 72A and indicated their position was that the local

fire alarms were supplementary alarms and therefore not required

to be electrically supervised. This position is a misinterpretation

of NFPA 72D and 72A.

For the control rocm visual alarm fire detection system annunciation

circuit, the licensee stated that the compensatory measures already

being taken were to have an operator verify the status of this

circuit once per eight hour shift. This is not equivalent to the

continuous electrical supervision that is required for this circuit

by NFPA 720 and 72A and is therefore unacceptable to Region III.

'

These deviations from the requirements of NFPA 72D and 72A constitute

a failure to comply with the approved fire protection program and

are a violation of Condition No. 24 of Amendment No.1 to Facility

Operating License No. NFP-11 (Unit 1) and Condition No.15 to

Facility Operating License No. NPF-18 (Unit 2) (373/86-004-01(DRS);

374/86-004-01(DRS)).

b. Fire Detection and Local Alarm Systemt Drawi_ng Discrepanc_ies

The inspector reviewed the fire detection and alarm systems as

delineated on the applicable electrical drawings and schematics

for technical adequacy, circuit presentation, standardization, and

conformance to regulatory requirements and industry standards.

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' The following observations were made:

(1) Schematic .Diagr!.m 1E-1-4033AJ,- Revision E, titled " Fire

Protection Central Relay Panel 1FP08J":

(a) Sub-titles under the functional portion of the circuitry

,

.

do not exist.

(b) Time delay relay ITDR does not contain time delay

, description.

i'

(c) Contact designation for push button IPB4 are missing.

> (d) Contact 2-4 of Relay 1ELX1 does not indicate a reference

drawing.

(2) Schematic Diagram 1E-1-4033AK, Revision C, titled "7.5KVA,

120VAC DC to AC Inverter (Panel IFP01E)":  ;

(a) -Breaker rating not indicated on breakers 1 through 8.

(b) 250A and 130A fuses internal to the inverter are i.' series

with 100A breaker upstream at the 125V DC emergency feed

to the inverter. This is of concern because normally the

sequence would be that higher rated breakers for' fuses

are placed upstream of the circuit.

(3) Schematic Diagram 1E-0-4421AH, Revision F, titled "RX Building

Local Control Box No. 2 (Panel 0FP02J)":

(a) Fire and evacuation sirens and local indicating lights

relating to the fire detection zones' circuitry are not ,

continuously monitored as required by NFPA 72D-1975.

(b) Siren and light circuitry do not contain a protective

fuse. A 15A breaker located at the IFP01E inverter is

used for circuit protection. Contact 2-4 of Relay IFR02

to this circuit failed open just prior to this inspection,

preventing reset of local fire alarms. In addition,

relay contacts in this circuit are rated at 2A resistive i

at 120VAC 60HZ per vendor drawing No. 005346, Revision 0. l

Therefore, it is possible that a current in the circuits i

of more than 2A could cause the contact to fail. This is

possible because-the only circuit protection is a 15A

breaker.

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(c) 120VAC feed to Relays 1ER02 and 1FR02 is noted on the

drawing as coming from inverter 1FP03E. Review of design

drawings indicated that it is presently fed from Inverter

IFP02E (which was verified to be a drafting error),

(d) Sub-titles.under.the functional portion of the circuitry

do not exist.

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(4) Connection Diagrams 1E-0-4604AF, Revision G, and 1E-1-4594AQ,

Revision J:

No observations made.

(5). No functional schematic diagram existed delineating the

continuously monitored fire detection circuits for the

detectors, end of line resistors, and alarm to the main

fire anrunciator panel (1FF04JB) in the main control room.

This (items 4.b(1), (2), (3), and 4.b(5)) is considered an Open

Item (373/86-004-02(DRS); 374/86-004-02DRS)) pending further

review by Region III.

c. Field Inspe_c_t_ ion of Inverters _an_d Panels

The inspector conducted a field visual inspection of in' *ers

.

IFP02E and 1FP03E, Fire Protection Panels IFP08J and 0Fi ,and

the control rocm alarm panel. Except for missing desigta. ions on

several relay contacts, no violations or deviations were identified.

d. Administrative Controls

In the LaSalle County Facility Operating License for Units 1 and 2,

it indicates that the licensee shall maintain in effect all provisions

of the approve <i fire protection program.

Supplement 2 of the Safety Evaluation Report dated February 1982,

Section 9.5.8 entitled " Appendix R Statement", states in part, "The

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applicant's fire protection program will meet the technical require-

ments of Appendix R to 10 CFR Part 50, and the applicant is

committed to meet guidelines for the administrative controls for

fire protection."

The Commonwealth Edison LaSalle County Station (LSCS) Units 1 and 2

response to the NRC's Request for Conformance to Branch Technical

Position (BTP) APCSB 9.5-1 (letter dated January 24, 1978 from

M. S. Turbok to A. Bournia), indicated that LSCS is in compliance

with the NRC position on Administrative Procedures and Controls.

Section B.1 of the BTP requires that administrative procedures

consistent with the need for maintaining the performance of the fire

protection system and personnel be provided. The inspectors reviewed

the licensee's procedure entitled " Fire Protection Program", numbered

LAP-900-14, Revision 9 dated September 4, 1985. The procedure

states "The purpose of this procedure is to define the Fire Protection

Program at LaSalle County Station by assigning responsibilities,

defining the organization, and providing infonr.ation and procedures

pertinent to fire protection.

The procedure outlines that the offsite members of the CECO staff for

fire protection are:

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(1) Division Vice President and General Manager - Nuclear Station

and Division ,

I (2) LSCS Quality Assurance Supervisor ,

(3) CECO Fire Protection Coordinator (Fire Protection Engineer).

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! (4) CECO Fire Protection Engineer

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The ensite responsibilities are assigned to:

(1) Fire Commissioner - Station Manager ,

,

] (2) Fire Marshall

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(3) Shift Engineer ,

l (4) Fire Chief

4

] No deviations were identified in this area except as noted in

Paragraph 2 of this report.

The inspectors also reviewed a selected sample of the licensee's

administrative controls established to minimize fire hazards such as

fire prevention procedure for welding and cutting, use of lumber and

i other combustibles in the plant, 6nd control of flamrc.able liquids.

l fio deviations were identified in this area.

1

e. Op_er.a_ tin.g_ Technical Specification Surveillances

Section 9.5.1.4 of the LSCS UFSAR states " Periodic inspections and

1 cperational checks to demonstrate integrity are routinely performed

"

on all fire protection systems. These tests and inspections are

r identified in the Technical Specifications."

t

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The inspectors reviewed the following technical specification *

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su'veillances: ,

, Technical Description of Procedure

Specification Surveillance Number

4.7.5.1.1.a Valve lineup LOS-FP-M3, Rev. 7

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1 Combined outside LOS-FP-M3

! fire protection

flow path valve

position

4.7.5.1.1.b Valve Cycling LOS-FP-A1, Rev. 3

4.7.5.1.3.a.1 Electrolyte LOS-DC-W1, Rev. 9

level above

plates.

,

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- - -

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4.7.5.1.3.a.2 Pilot Cell LOS-DC-W1, Rev. 9

specific gravity

4.7.6.2.e Inspect auto hold- LTS-1000-14

open, release and

closing mechanism,

and latches at least

once per 6 months

Areas reviewed that were found unacceptable are discussed below: ,

Fire Pro _tection_ Valve Surveillances

The inspectors reviewed " Fire Protection Flow Path Valve Cycling

Test (FPFPVCT)," Procedure No. LOS-FP-A1, which requires the

valves in the open position in the fire protection system to be

lubricated and cycled once every six months. This procedure '

requires three attachments of Procedure LOS-FP-M3, entitled " Valve

Lineup (VL)", which identify the valves to be lubricated and

cycled to be utilized and attached to the FPFPVCT surveillance.

The inspector could not verify that all the valves required to be

lubricated and cycled per FPFPVCT procedure were completed because

the three VL surveillances were not attached as required. Instead,

several of the individuals performing the surveillance signed the '

FPFPVCT surveillance and included a note to see the VL surveillance.

The inspector reviewed the VL surveillance and noted that one

individual that had not signed FPFPVCT surveillance was on the VL

surveillance and it was not known if the valves this individual had

signed off on in the VL surveillance were cycled as per FPFPVCT

procedure. The individual was questioned by the NRC inspectors and

it was concluded that the individual conducted the FPFPVCT procedure.

The procedure will be revised to insure that adequate documentation

will be available to insure that valves in the fire protection system

have been properly lubricated, cycled, ard locked in the proper

position. This is considered an Open Item (373/86004-03(DRS);

374/86004-03(DRS)).

Procedures for Firefighting Foam

The inspectors observed two types of 31% firefighting foam concentrate

(produced by two different manufacturers) in the fire protection

equipment area in the Unit 2 turbine trackway located at R-27 Eleva-

tion 710. At the request of the inspector the licensee contacted

the manufacturers to verify if the foams could be used together. The

manufacturers indicated that the foams are incompatible. The licensee

took corrective action and separated the two types of foam. As

discussed with the licensee, there is 50 gallons of one type of foam

which will be stored in the warehouse and used only for fire brigade

trai.ning purposes. In addition, the licensee indicated that only one

type of foam will be utilized at this facility. The licensee

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indicated that procedures were being developed for the fearc concen-

i trate to insure that it is tested according to NFPA and manufacturers'

,

instructions. This is considered an Open Item (374/86004-04{GRS)).

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Oppli_ty Assurance Program

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The Safety Evaluation Report dated April 3,1981, Section 9.5.7,-

! stated that the applicant has agreed to implement the fire protection

1 program contained in NRC supplemental guidance document Huclea'r ,

Plant Fire Protection Functional Responsibilities, Administrat5ve

Controls and Cuality Assurance," dated August 29, 1977.

The inspector's review of the licensee's Quality Assurance Program

i included review of the following:

'

(1) Quality Assurance Audit' Report dated August 2, 1984-and

July 31, 1985.

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, (2) Audit Checklist and Record Sheet 01-BS-1, March 19-22,1985,

and 01-BS-11, September 10-13, 1985.  !

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(3) Triannual Audit by M and M Protection Consultants dated .

December 4,1984.

j No violations or deviations were identiffEd.

8. Open Items

Open items are matters which have been discussed with the licensee, which  ;

I

will be reviewed further by the inspector, and which involve some action 3

on the part of the NRC or licensee or both. Open items disclosed during

the inspection are discussed in Paragraphs 3, 4.b, and 4.e.

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i 9. Exit Interview

! The inspectors met with the licensee representatives at the conclusion of

the inspection on January 27, 1986, and sucraarized the scope and findings

i of the inspection. The licensee acknowledged ttte statemerts trade by the

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inspectors. The inspectors aIso discussed the likely informaticnal

content of the inspection report with regard to documents reviewed by the

inspector during the inspection. The licensee did not identify any such

,

dccuments as proprietary. Subsequently, in a telephone conversation with

the licensee, additional concerns regarding failure to install fire

detection and alarm 17;tM.:s in accordance with governing code requirements

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were discussed with the licensee.

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