ML20239A371

Insp Repts 50-373/87-27 & 50-374/87-26 on 870713-0908. Violation Noted.Major Areas Inspected:Allegations Re Adequacy of Training Provided to Fire Brigade Members & Qualifications of Members Responsible for Fire Protection

ML20239A371
Person / Time
Site:	LaSalle
Issue date:	09/11/1987
From:	Gardner R, Ulie J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20239A335	List: IR 05000373/1987027 ML20239A333 ML20239A352 ML20239A371
References
50-373-87-27, 50-374-87-26, NUDOCS 8709170294
Download: ML20239A371 (15)

See also: IR 05000373/1987027

Text

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Heport lic9 50-373/87027(DRS); 50-374/87026(DRS)

Docket Nos.30-373; 50-374 Licenses No. NPF-11; NPF-18

Licensee: Commonwealth Edison Company

P. O. Box 767

Chicago, IL 60690

Facility Name: LaSalle County Station, Units 1 and 2

Inspection At: LaSalle Site, Marseilles, Illinois

Inspection Cunducted: July 13-15, August 10-11 and September 8, 1987

4 @ M . LG. gy

Inspector: oseph M. Ulie

Date

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Approved By: Ronald N. Gardner, Chief 9H 07

Plant Systems Section Date

Inspection Summary

Inspection on July 13-15, August 10-11 and September 8, 1987 (Reports No.

50-373/87027(DRS);

No. 50-374/87026(DRS))

Areas Inspected: Special, announced inspection to review action (s) taken

by the licensee relative to allegations concerning the adequacy of training

provided to fire brigade members and qualifications of certain staff members

responsible for the licensee's fire protection program (54834, 92701, and 99014).

Results: Within the one area inspected, one violation was identified

(Procedure inadequacy in that the procedure did not prescribe the need

for fire brigade assistance upon receipt of an alarm in the control

room - Paragraph 2).

8709170294 870911

PDR ADOCK 05000373

0 PDR

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DETAILS

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1. Persons' Contacted

Commonweatlh Edison Company (CECO)

• R. D. Bishop, Services Superintendent

. *D. A. Brown Quality Assurance Superintendent

,  :*W. G. Collins, Assistant Fire Marshal

• R. Crawford, Training Supervisor

C. J. Diaz, Support Services.

G. J. Diederich, Station Manager

D. J. Enright Quality Assurance Engineer

• T. A. Hammerick, Technical Staff Services

T. G. Hausheer, Station Support Services

J. R. Kodrick, Maintenance Staff Engineer

P. G. Kuhel, Supervisor of Station Support Services

, *J. C. Renwick,' Production Superintendent

'*M. H. Richter, Technical Staff

• M. Schaible, Fire Brigade Instructor

• W. A. Steffes, Fire Marshal

• D. G. Trager, Group Leader Training

US NRC

• M. J. Jordan, Senior Resident Inspector

The inspector also contacted other licensee personnel during the

inspection visit.

• Denotes persons attending the exit interview of August 11, 1987.

-2. Review of Actions Taken by the Licensee Regarding Previous Fire Protection

Allegations

On January 13-27, 1986, NRC inspectors performed inspection activities

relative to allegations received by the NRC from an individual outside

of the licensee's organization. These allegations pertained to the

adequacy of training provided to fire brigade members and qualifications

of certain staff members responsible for the licensee's fire protection

program (at LaSalle County Station). Based on the NRC's direct

inspection; review of pertinent fire brigade records and brigade training

programs; and interviews with cognizant licensee personnel, this allegation

was determined to be substantiated. Further, as a result of that review,

it was determined that no explicit regulatory requirements were violated,

however, the concerns expressed by the alleger did possess merit.

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Consequently this inspection visit (July 13-15 and August 10-11,1987)

was-performed to follow through in reviewing any reevaluation or

corrective action (s) taken by the licensee. This included any resulting

implementation actions-initiated by the licensee having an affect on fire-

protection personnel, their training or their qualifications as related

to applicable NRC referenced gu'delines or requirements. Below are the

conclusions of this inspection visit including a lead-in reference to

each of the allegers' allegations and inspector review results as

described in the initial followup Inspection Report (373/86004; 374/86004).

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a. 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.

During the January 13-27, 1986, inspection visit, the inspectors I

described seven deficiencies determined as a result of the above

allegation review and concluded that this allegation was

substantiated. It is the licensee's response to these seven

deficiencies that was evaluated and detailed during this

inspection (July / August 1987) as follows:

(1) Fire brigade drill critiques were incomplete in some instances

because they did not contain an adequate assessment of the

drills. Specifically, none of the drill critiques examined

made any assessment of individual fire brigade member performance

during drills (i.e., physical, mental and emotional fitness to

perform the required duties).

During this inspection, the inspector requested and was provided

Crew No. 3 drill records dated March 1986 through July 1987.

Attached to these records were the applicable drill critique

sheets. These drill critique sheets included the sequence of

events; overall brigade performance; a list of recommendations;

use of equipment; fire alarm effectiveness; response time of

brigade personnel; performance of fire brigade personnel;

assessment of brigade members knowledge; brigade members role

in fire fighting operations including strategy; and the fire

brigade leaders' direction, thoroughness, and accuracy of the

brigade leaders' role. The inspector's review of the fire

brigade drill records revealed that twenty-six (26) of the last

thirty (30) drills held included handling and use of onsite fire

hose (various sizes) equipment.

According to the licensee's onsite fire protection personnel

and as confirmed by the inspector through record review; of

these 26 drills, nine (9) drills were conducted which included

actual charging of the hose lines and the flow of water outside

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of vital plant areas. This was done to provide the brigade

members involved with a more enhanced drill exercise. Discussions

between fire brigade members and the inspector identified this

type of drill exercise to be an effective method in maintaining

positive fire brigade morale.

During inspector review of the drill critiques, it was noted

that the drill observers (Station Fire Marshal or his designee

who critiqued the drill) made mention of the brigade members'

actions including their overall fitness (i.e., mental and

physical status) in accomplishing the training drill (s)

objectives .

The inspector verified that the " Strategy and Tactics"

lesson plan for the newly adopted " Training Standard For

Nuclear Station Fire Brigade Members" does provide

guidelines for the brigade leader in coordination with

the shift engineer for determining the need for offsite

fire department assistance. The inspector indicated that

future drill critiques would be enhanced by specific

observations on a periodic basis by the observer regarding

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

fire department assistance. This is provided for in the

" Strategy and Tactics" lesson plan and through accepted fire

protection industry practice. The licensee's staff acknowledged

that this observation would be noted in future drill critiques.

Further, the inspector encouraged the licensee's staff to develop

a pre-printed fire drill critique checklist to aid the individuals

performing fire drill critiques and so as to provide a more

consistent review by these personnel.

With regard to the fire brigade member's physical fitness to

perform their required duties, the inspector selected three fire

brigade members' names from a fire brigade roster and verified

that these individuals had received an annual physical exam.

These physical exams are performed through a CECO program

commonly referred to as the Health Evaluation Program (HEP).

During a conference call held on July 15, 1987, between

the Station, Corporate CECO, and the inspector, the CECO

Administrator - Medical Director specified that the HEP

exam meets the annual physical examination requirement for

determining the fire brigade member fitness. A subsequent

telephone call on August 7, 1987, between the CECO Medical

Director and the inspector confirmed that certain specific

tests are administered during this exam such as a pulmonary

function test, cardiological related tests and other tests

that provide medical data in determining the fitness of an

individual for fire brigade duty. Based on NRC criteria and

licensee commitments, the inspector determined the level of

the exam in determining fire brigade member fitness to be

satisfactory.

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As part of another element in determining the. adequacy of

fire brigade. training, the inspector requested the licensee -

l to conduct an unannounced fire drill of the on-duty operations

shift personnel.

As committed to by the licensee,- Section III.I of Appendix R

indicates that fire brigade drills shall.be performed in the

plant so that the fire brigade can practice as a team;,the

drills shall be preplanned to establish the training objectives

of the drill, and the drills shall be critiqued to determine

how well the. training objectives of the ' drill have been met.

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These requirements were also in the NRC document, " Nuclear

Plant Fire Protection Functional Responsibilities,

-Administrative Controls and Quality Assurance," dated June 1977

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committed to by the licensee as described in the original Safety

Evaluation Report (SER) and SER Supplement No. 2.

The inspector requested a' fire scenario which would include an

observation of the fire brigade demonstrating firefighting

techniques (including fire hose handling) and also the adequacy.

of communication interface between the fire brigade and radiation ~

tontrol technician (RCT) personne1' during fire emergency conditions. -

The fire drill postulated an electrical initiated fire involving

480V MCC.136Y-I in the Unit 1 Reactor Building. The postulated

fire affected MCC cable insulation'and spread to six contaminated

bags of anti-contamination clothing behind the panel. The

inspector reviewed both the fire drill scenario and pre-fire plan-

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which included a walkthrough of the " fire" area. prior to the

drill.

In preparing to witness the fire drill, the inspector reviewed

appropriate portions of licensee procedures which relate to

fire discovery and subsequent fire extinguishment as follows:

(a) . LAP-900-17, Fire Drills, Revision 6, dated October 17,

1984;

(b) LAP-900-14, Fire Protectics Program, Revision 11 dated

October 27, 1986;

(c) LZP-1340-2, Implementing Procedure For Fire: Fire

Chief (Designated Shift Foreman), Revision 2, dated

March 15, 1983;

(d) LZP-1340-4, Implementing Procedure For Fire: Fire

Brigade, Revision 1, September 17, 1981;

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(e) -LZP-1220-1, Emergency Telephone Number, Revision 1,

May 18, 1981;

(f) LZP-1210-1, Hazardous Material Incidents Reporting,

Revision 6, April 21, 1986; and

(g) LOA-FP-01, Fire A'iarm Response, Revision 5, March 23,

1987.

This fire drill was an unannounced drill having been-

initiated on July 14, 1987, at approximately 1700 hours0.0197 days <br />0.472 hours <br />0.00281 weeks <br />6.4685e-4 months <br />.

The inspector .was stationed initially in the control room

u to observe the actions taken by the Nuclear Shift Operator

L (NS0) upon receipt of the fire alarm (a fire detector in

the " fire" area was activated by licensee personnel).

Enroute to a fire brigade station (fire equipment cage) the

inspector observed the arrival of the fire brigade leader at

the postulated fire scene to' perform necessary size-up actions.

lipon inspector arrival at the brigade station, seven members of

the fire brigade were observed assembling and donning firefighting

protective clothing. The inspector evaluated the fire brigade

and support personnel actions in determining and observing-the .

following: (1) fire brigade members' conformance with established

plant firefighting procedures; (2) an assessment of the fire

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brigade leader's direction of the fire fighting efforts;

(3) actual donning and simulated use of the self-contained

breathing apparatus (SCBA); (4) actual donning of protective

clothing; (5) simulated use of two 11" fire hose st e io w

(6) use of portable radio communication equipment;-(7) brigade

timeliness in response and numbers of personnel responding with

proper firefighting equipment and (8) brigade leader interaction

with the RCT and other support personnel (e.g., security

on scene). In addition, approximately five additional on-shift i

personnel were observed aiding in auxiliary brigade activities.

The inspector determined the above actions were performed

satisfactorily. The overall inspector assessment of the drill,

which was based on inspector observations and post drill critique

discussions, concluded that the fire drill was performed

satisfactorily. The inspector did, however, observe the

following five discrepancies:

(a) Two brigade members on the back-up hose line failed to

don their SCBA. The importance of wearing the breathing

apparatus even during drill exercises needs to be emphasized

to the fire brigade members especially where potential

airborne radioactivity and contamination concerns exist.

An acknowledged difficulty duhing fire drill activities

is the lack of products of combustion, yet this should not

negate the wearing of full protective clothing including

SCBA during fire drill scenarios. This is described in

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' Attachment No.: b (Section e) of the NRC document, " Nuclear

Plant Fire Protection Functional Responsibilities,

Administrative Controls, and Quality Assurance."

-(b) One brigade member while donning his SCBA identified what

was believed to be a defective regulator on-his unit causing

a short delay in having this individual actively participate

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in' the drill activities while a different SCBA was donned.

L (c) One of the RCT's respon' ding to the fire scene was unable

to gain entry:to the Reactor Building due to two separate

air lock doors having been .left open.

(d) Although not part of the drill, the inspector in discussion

with the fire brigade, learned that a clearer understanding

of the Station Policy on the use~ of elevators during fire

response (s) needed to be clarified or reemphasized (e.g.,

gaining control of the elevator and use of the elevator

for transporting fire brigade equipment carts, etc.).

The above four discrepancies are considered an open item

(373/87027-01; 374/87026-01) pending NRC followup of the

licensee actions regarding the above discrepancies.

(e) Although ~ timely assembly of the fire brigade and response

to the fire scene occurred during the inspector witnessed.

fire drill, an additional discrepancy was identified

regarding a Station Policy as described in the " Fire Alarm

Response" Procedure No. LOA-FP-01, Revision 5, dated

March 23, 1987. When an unplanned fire alarm activation

is received on the Control Room annunciator panel an

operator is dispatched to the fire alarmed area to

investigate whether an actual fire is present or not.

The procedure did not prescribe the need for brigade

assistance upon receipt of an alarm in the control room.

The fire detection system is installed to provide early

notification of a fire conditioi; yet the licensee t as

unable to provide justification for not relying on this

indication upon initial receipt and assembling the fire

brigade.

The present Station Policy creates the potential for a

delay in alerting and assembling the fire brigade after

an unplanned actuation of a fire alarm has occurred and

allows the potential fire to freely spread unsuppressed.

As described in the SER and Supplemental No. 2, the

licensee committed to the NRC " Nuclear Plant Fire Protection

Functional Responsibilities, Administrative Controls and

Quality Assurance" document. Attachment No. 5 of this

document identifies that the firefighting procedures should

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identify actions to be taken by the control room' operator

-and.the need for. fire brigade assistance upon' receipt of a

fire alarm on:the control room annunciator panel. As

l. previously mentioned, the licensee's " Fire Alarm Response",

' Procedure Number LOA-FP-01 did not prescribe the need for

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fire brigade assistance upon receipt of an alarm in the~

L control room.

The abov'e failure to prescribe the'need for brigade,

assistance upon receipt of an alarm in the control.

room is considered a violation (373/87027-02;

374/87026-02) of the Facility Operating License for

Units 1 and 2 as is described in the Notice of Violation.

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In addition, a-telephone conference call (requested by the

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licensee) was held between members of the licensee's staff

I. (Corporate and Station) and Region III staff (Messrs.

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R. Gardner and J. Ulie) on September 8,1987, to further

l discuss this inspector raised concern.

The inspector's review concluded that the licensee had

satisfactorily resolved the item (1) portion of the

L identified deficiencies.

L (2) Fire hose stations-appear to have been used in the drill

l simulations.but according to the licensee's staff, fire

brigade training has been largely focused on the use of

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portable fire extinguishers.

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l Duringthis' inspection,asmentioned'in(1)above, inspector

review of the fire. brigade drill records dated March 1986

, through July 1987 revealed that 26 of the last 30 drills held

included handling and use of onsite fire hose (various sizes)

equipment during those drills. In addition, according to the

licensee's onsite fire protection personnel and as confirmed

by tho inspector through record review of these 26 drills

conducted, nine~ drills were conducted which included actually

charging hose lines and the flow of water outside of vital

plant areas.

In addition, during the annual fire brigade training held

during the Fall of 1986, all fire brigade members received

hands-on hose handling training under live fire conditions.

The inspector selected 15 fire brigade members' names from

a fire brigade rcster and confirmed that each of these

individuals names were listed showing that they had

attended the 1986 annual fire brigade training session.

The inspector also witnessed this type of training for seven

g members of the LaSalle Fire Brigade on August 10, 1987, held

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at the Braidwood Fire Brigade Training Facility. The inspector

determined that adequate training is now being conducted.

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The inspector's review concluded that.the licensee had l

satisfactorily resolved this portion of the identified

deficiencies.

(3) All fire brigade members have not been trained in the use of - {

handling fire hose streams at pressures found at LaSalle while

fighting internal structure fires.

During this inspection the inspector determined, based on selected

inspector review and according to the licensee, that all LaSalle

fire brigade personnel were provided hands-on fire hose handling

training under charged and flowing water conditions during live

fire evolutions. This training was provided at the Braidwood

Fire Brigade Training Facility in 1986 to satisfy the annual

brigade training requirement. According to a member of the

licensee's corporate fire protection staff, the Braidwood fire

pump operating pressure is at least equivalent to or greater

than the pressures the LaSalle fire brigade would experience.

On August 10, 1987, while the inspector was at the Braidwood

Facility, the licensee demonstrated this assertion satisfactorily.

In addition, when the LaSalle fire brigade members trained

with the charged hose lines outside of vital plant areas at

LaSalle, those hose lines were connected directly to fire

hydrants which have pressures which are greater than or

equivalent to that which the fire brigade would expect to

experience with inside hose lines.

Consequently, the inspector's review concluded that the

licensee had satisfactorily resolved this portion of the

identified deficiencies.

(4) No documentation was provided to verify that all fire brigade

members received portable fire extinguisher training prior to

becoming a fire brigade member.

During this inspection, the licensee provided the inspector a

copy of the firefighting evolutions conducted during the initial

and annual training which does include hands-on practice using

portable fire extinguishers. Subsequently, the inspector selected

15 fire brigade members' names from a brigade roster and verified

that those names were listed on the attendance list for the 1986

annual fire brigade training session.

In addition, the inspector also witnessed this type of training

for seven members of the LaSalle Fire Brigade on August 10,

1987, held at the Braidwood Fire Brigade Training Facility. The

inspector determined that adequate training is now being

conducted.

I The inspector's review concluded that the licensee had

satisfactorily resolved this portion of the identified

deficiencies. l

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(5) Enhancements are needed in the licensee's smoke house training

facility.

During this inspection, the inspector was informed that the

licensee performed a reevaluation on a corporate-wide basis

.of the CECO Fire Brigade Training Program as described in an

internal licensee letter from the CECO Corporate Division -

Vice President to CECO Nuclear Station Managers dated April 14,

1986. As a result, according to the licensee, an improved

program entitled, " Training Standard for Nuclear Station Fire

Brigade Member," approved on July 6,.1987, has been developed.

As part of this Training Standard a fire brigade member

certification guide and instructor lesson plans have been

developed and are considered approved for the CECO Fire Brigade

Training Pilot Program (Interim). This program was nearing

final approval and was planned to be fully implemented in the

near future.

On August 10, 1987, the inspector toured the Braidwood Fire

Brigade Training Facility and observed fire brigade training

exercises in progress. These training exercises included

hands-on fire extinguisher and fire hose handling on live fires

inside and out of the training tower (burn building). The

inspector determined that the type of fire brigade training

being provided at this facility is a significant improvement

from past practice and meets NRC requirements as comitted to

by the licensee. Presently, three CECO Nuclear Station Fire

Brigades (Braidwood, Dresden, and LaSalle) are utilizing the

Braidwoo6 Fire Training Facility. l

The inspector's review concluded that the licensee had

satisfactorily resolved this portion of the identified

deficiencies.

(6) No objective measurement is made of individual brigade member's

comprehension of the fire brigade classroom training because

written or oral qualifying examinations are not administered on

any of the subject matter at any time. Furthermore, the initial

20 hour2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br />. classroom training session does not contain the quality

and depth of training that is intended by the requirements of

Chapter 4 of National Fire Protection Association (NFPA) 27 or

NRC guidelines.

During this inspection, the inspector was informed by the

licensee that a policy change has occurred since the original

inspection in that written exams are now being given at the

completion of the initial training program. The inspector

reviewed the written exam questions and determined that the  !

fire protection level of understanding being required by the l

exam is satisfactory. At the time of the July inspection visit, l

one crew of brigade members had been tested under a pilot program

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with subsequent implementation of this type of testing planned

during the Fall of 1987. According to the licensee's staff, the

initial fire brigade training program has been revised from a

twenty (20) hour program to a forty (40) hour program, thereby,

expanding and providing more instructional depth than in the past.

The inspector performed a comparison review of the newly

developed fire brigade instructor lesson plans, Revision 0, to

the general guidelines of NFPA 27-1981 and to the nationally

recognized fire service training manuals (IFSTA), and determined

that the lesson plan subjects do incorporate the subject content.

The inspector's review concluded that the licensee had

satisfactorily resolved this portion of the identified

deficiencies.

(7) The licensee's' employment policy is not consistent with

the requirements of Paragraph 3-2.3.3 of NFPA Standard

No. 27, which states, "Only persons meeting physical,

mental and emotional requirements should be considered

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

not established mental and emotional requirements for fire

brigade members.

During this inspection, the licensee provided the inspector with

a letter dated July 10, 1987, describing the testing process all

employees are subjected to including specific tests given to

potential fire brigade candidates. These tests include a

physical exam, psychological screening test, plant operator

selection system test and the initial fire brigade training

program (classroom and hands-on training provioed).

Fire brigade members receive an annual physical examination

thru the HEP which includes a pulmonary (respiratory) examination

among other tests. Since no additional specifics regarding

physical requirements are provided in Paragraph 3-2.3.3 of NFPA

Standard No. 27, the depth of this physical exam was determined

adequate.

In addition, according to NRC Operator Licensing personnel,

those fire brigade members who are also nuclear reactor

operators are also reviewed by the NRC against certain

medical criteria as described in ANSI N546.

According to a member of the licensee's fire brigade training ,

staff, instructors also observe fire brigade members during

training activities for signs of physical inability or emotional l

distress.

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On August 10,31987, the inspector, while attending a fire

brigade training session, observed the fire brigade members

for any signs of apparent physical or emotional difficulty-

(i.e., donning.and use of the SCBA, physical activities

required during _firefighting). No unusual difficulty was

observed during this training session.

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The inspector's review concluded that the licensee had

satisfactorily resolved this portion of the identified

deficiencies.

As a result of the above seven deficiencies having been

satisfactorily addressed by the licensee, allegation (a) is

considered resolved.

b.- Training department personnel were not qualified technically to give

fire brigade training.

, During the January 13-27, 1986, inspection this allegation was

substantiated because of the fire brigade training instructor's

minimum qualifications, and because the outside firefighting

training that satisfies the NFPA Standard No.'27 was not being

provided to fire brigade members.

During this inspection, the inspector performed a review of those

individuals' qualifications (regarding the Station Assistant Fire

Marshal,. refer to Paragraph 2.d) who according to the licensee are

assigned as the LaSalle fire brigade training instructors. In

performing this review the inspector used the licensee committed to

NRC document entitled " Nuclear Plant Fire Protection Functional

Responsibilities, Administrative Controls and Quality Assurance" which

was described in two SERs dated March 1981 (Original) and February 1982

(Supplement No'. 2). Further,-the inspector used the NFPA National

Fire Codes No. 27 - 1975 edition (in effect at the time the Station

Construction Permit was issued) during this review.

The inspector was provided a copy of the fire brigade training

instructor qualification sheets. As specified in these sheets,

this individual was in active status at a volunteer fire department

during a three year period and reserve status for an additional

three years. In addition., these documents show that over a seven

year time frame this individual performed as a member of a Naval

Damage Control Team including approximately three years as an

Office-In-Charge of the Damage Control Team. This documentation

shows further that this individual had attended several firefighting

training program sessions over a fourteen year period. This

individual had documentation to demonstrate that he is also a

l- certified CECO instructor.

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In addition,Tduring discussions with this indiv'idual. the inspector

learned that:this individual was scheduled to attend an Illinois' '

Certified Firefighter. Level II class-being conducted by the

University _of _ Illinois during September and October 1987.

According to the licensee's staffi this. instructor, when giving

, hands-on fire brigade instruction, works in cooperation with the'

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Station Assistant Fire Marshal. The Station Assistant Fire Marshal-

has attained an Illinois Advanced Certified-Firefighter III

Certification. ~On August 10, 1987,'during the training session-

attended by the inspector at the Braidwood Facility, the designated

Braidwood Fire Brigade Instructor and the designated primary' LaSalle

,. Fire Brigade Instructor provided all the fire brigade instruction.

while the LaSalle Assistant Fire Marshal performed more of a

supportive role during the various fire fighting evolutions.

The specific' wording in the NRC Fire Protection Functional

Responsibilities document' only states, " personnel responsible for

the training of the fi_re brigade should be qualified by training and-

l experience for such work."

Based on the non-specificity of the NRC requirements as committed

.to by the licensee and the inspector's review including interviews

with the. cognizant licensee personnel, the inspector concluded.that -

the licensee was meeting NRC requirements.= However, to enhance the

qualifications of all fire brigade instructors, the inspector'

encouraged the licensee's management at the exit meeting on August 11,

1987; to support these individuals in attaining their. State Fire

Service Instructor Certifications so as to better develop their

skills and knowledge in the. fire protection area.

Consequently -this allegation was determined to be satisfactorily

resolved.

c. Training department and station management have not supported fire

brigade training.

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During the January 13-27, 1986, inspection it was determined by

review of fire brigade training records and through interviews

with cognizant licensee personnel that this allegation was

substantiated. During that inspection a review of selected fire

brigade member training records revealed that fire brigade members

were not receiving outside special hazards training in internal l

structural firefighting. Furthermore, the licensee's training and

management staff acknowledged the discontinuation of fire brigade

training in the use of (li") line hose streams due to operations

problems with the station fire pumps.

l

l

l

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.

.

During this inspection, as already mentioned, the licensee now provides

training in internal structural firefighting on an annual frequency

for each fire brigade member. In addition, fire brigade training

records dated March 1986 through July 1987 indicated that 26 of the

last-'30 drills held included handling and use of onsite fire hose

equipment. Nine of these drills included actually charging hose

. lines and the flow of water outside of vital plant areas. This type

of training was encouraged by the inspector to be maintained by the

licensee.

Also the inspector was provided an internal licensee memo addressed

to CECO Nuclear Station Managers from the CECO Corporate Division

Vice President dated April 14, 1986. This memo provided the

Corporate Nuclear Station Division position in supporting interior

structural live firefighting practice as part of the nuclear

station's fire brigade training and requested this type of training

be accomplished at each nuclear station.

According to the fire brigade instructor, Station management has

approved the brigade instructor's uttendance at a six week Certified 1

Firefighter II level course scheduled for the Fall of 1987.

The inspector's review concluded that the licensee had satisfactorily

resolved this allegation.

d. The Station Fire Marshal was not qualified technically.

The NRC has not specified any formal qualification requirements for

the position of Fire Marsiul; however, during the January 13-27, 1986

inspection, it was determined by review of the Station Fire Marshal's

qualifications, and through interviews with cognizant licensee  !

personnel that this allegation was substantiated.

During this inspection, the inspector learned from the licensees'

staff that changes in personnel have occurred in the Station Fire

Marshal's position.

The licensee's staff provided the current Fire Marshal's resume and

the Assistant Fire Marshals' resume to the inspector for review.

The Fire Marshal's resume indicated achievements as an Illinois

State Certified Firefighter Level II certification, having attained

special fire protection training while enrolled in several {

firefighting courses and more than six years service as a volunteer

firefighter. The Assistant Fire Marshal's resume listed achievements

including an Associate in Applied Science Degree in Fire Science

Technology; a planned completion in the Fall of 1987 of a Bachelor

of Science Degree in Fire Administration; seven years of service as

a volunteer firefighter having approximately four of those years in l

a fire department officer position; and also having attained an

Illinois State Certified Advanced Firefighter III level certification. j

The inspector's review included interviews with the cognizant

licensee personnel.

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i

,

?

,

The inspector's review concluded that the licensee had satisfactorily

I-

resolved this allegation.  !

e. Tests were not administered after fire brigade training.

During the January 13-27, 1986, inspection it was determined that

examinations were not administered on any subject at anytime.during

the licensee's fire brigade training program. Based on the NRC

inspection, this allegation was substantiated.

During this . inspection, a member of the licensee's training staff

provided a copy of a 58 question written exam for review. This i

exam is now being given to fire brigade members at the conclusion

'

of the initial fire brigade training program. The inspector performed

a review of this exam and determined the test questions level of  ;

difficulty to be appropriate for the level of understanding expected )

of fire brigade personnel.  !

The inspector's review concluded that the licensee had satisfactorily l

resolved this allegation.

'

3. Housekeeping

On July 14, 1987, an ir.::peetor, while accompanied by members of the i

licensee's staff, performed a walkthrough of certain areas in the Reactor

and Turbine Buildings to determine the adequacy of station personnel in

maintainingtheStationcleanliness(housekeeping). These areas included ,

elevations 710', 740', and 761' for Unit 2 in the Reactor Building;

elevations 786' and 820'.for both Units 1 and 2; and elevation 768' of

the Turbine Building which is common to both Units. After a walkthrough 1

of these areas by the inspector, it was determined that the cleanliness  ;

of those plant areas were being maintained in a satisfactory condition.

4. Open Item

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

will be reviewed further by the inspector, or which involve some action j

en the part of the NRC or licensee or both. An open item disclosed  ;

during the inspection is discussd in Paragraph 2 of this report.

5. Exit Interview J

The inspector met with licensee representatives (denoted in Paragraph 1)

at the conclusion of the inspection on August 11, 1987, and summarized the

scope and findings of the inspection. The inspector also discussed the

likely informational content of the inspection report with regard to

documents reviewed by the inspectors during the inspection. The licensee

did not identify any of the documents as proprietary. In addition, a

telephone conference call (requested by the licensee) was held between

members of the licensee's staff (Corporate and Station) and Region III

staff (Messrs. R. Gardner and J. Ulie) on September 8, 1987, to further

discuss the inspector raised concern regarding the adequacy of the Station

" Fire Alarm Response" procedure.

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