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{{Adams | |||
| number = ML20154B737 | |||
| issue date = 02/27/1986 | |||
| title = 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 | |||
| author name = Falevitz Z, Guldemand W, Guldemond W, Holmes J, Ramsey C | |||
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) | |||
| addressee name = | |||
| addressee affiliation = | |||
| docket = 05000373, 05000374 | |||
| license number = | |||
| contact person = | |||
| document report number = 50-373-86-04, 50-373-86-4, 50-374-86-04, 50-374-86-4, NUDOCS 8603040383 | |||
| package number = ML20154B698 | |||
| document type = INSPECTION REPORT, NRC-GENERATED, INSPECTION REPORT, UTILITY, TEXT-INSPECTION & AUDIT & I&E CIRCULARS | |||
| page count = 19 | |||
}} | |||
See also: [[see also::IR 05000373/1986004]] | |||
=Text= | |||
{{#Wiki_filter:- _ - . | |||
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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 | |||
i | |||
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 | |||
b | |||
/ | |||
. Holmes ' | |||
Mb | |||
'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 - | |||
PDR | |||
l | |||
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. _ . - - ._ _ -. . | |||
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' | |||
DETAILS | |||
1. Persons Contacted | |||
*G. Diederich, Station Manager | |||
*R. Bishop, Services Superintendent | |||
l C. Allen, Nuclear Licensing Administrator | |||
> | |||
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 | |||
' | |||
l *J. Kodrick, Maintenance Staff Engineer | |||
- | |||
*B. Collins, Assistant Fire Marshal | |||
*P. Manning, Technical Staff Supervisor | |||
*A. Settles, Assistant Technical Staff Supervisor | |||
' | |||
*T. Hammerich, Assistant Technical Staff Supervisor | |||
*M. Jeisy, QA Supervisor | |||
*T. Gallagher, QA | |||
*J. Kocek, Technical Staff | |||
' | |||
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 | |||
! | |||
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 | |||
, | |||
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 | |||
t | |||
4 | |||
- . - -- .-. . - _. _.- | |||
. - .- - . . . ___ _ - . | |||
- - | |||
. | |||
. | |||
, | |||
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 | |||
' | |||
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. | |||
. | |||
(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 | |||
4 | |||
' | |||
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: | |||
3 | |||
, -. __. . -. - ,_ . - . - - , - - . , -, , | |||
v A y,e - & -- m.4~ -- .L w u4 | |||
' | |||
. . | |||
, | |||
, | |||
a. Reactor water level and pressure | |||
b. Suppression pool level and temperature, and | |||
1 | |||
c. Diagnostic instrume.tation for shutdown systems, | |||
] | |||
i The licensee has. supplied instrumentation to monitor reactor water level | |||
4 and pressure, suppression pool level and temperature, RHR service water | |||
j | |||
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- | |||
l | |||
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. , | |||
1 | |||
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 | |||
' | |||
assurance acceptance / rejection criteria as required by NFPA codes and | |||
i standards: | |||
i | |||
' | |||
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 | |||
l | |||
and Cycling Test." | |||
e. LMS FP06, " Fire Protection hose Station Valve Operability and Flow | |||
Verification." | |||
; No deviations were identified except those noted below: | |||
i | |||
, | |||
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- | |||
. | |||
satisfy Technical Specification Surveillances. | |||
Procedure LOS FPA3 " Fire Protection Sprinkler and Deluge System Drain | |||
Flow and Cycling Test" outlines the steps necessary to: | |||
1 | |||
1,. | |||
.i | |||
' | |||
-4 | |||
- _ _ _- . _. .- - , . ~ . _ , _ _ _ . _ . . . - _ . _ . - . _ _ _ _ _ | |||
_ _ | |||
_ - . - _ . _ __ . __ __ | |||
,- .~ | |||
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. | |||
, | |||
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. | |||
- | |||
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 | |||
- | |||
decision was made in this regard. | |||
5 | |||
. | |||
,- .- | |||
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. | |||
' | |||
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 | |||
l | |||
portable fire extinguishers. | |||
; | |||
, | |||
(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 | |||
. | |||
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. | |||
6 | |||
: | |||
- _ _ _ _ _ _ _ . _ _ - - _ _ _ _ - _ - _ _ _ _ _ _ _ _ - - - _ - _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ | |||
. . . | |||
- - | |||
. | |||
. | |||
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 | |||
' | |||
administered on any of the subject matter at any time. | |||
Furthermore, an initial 20 hour 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 | |||
i | |||
eligible to serve on the fire brigade." The licensee has | |||
# | |||
not established mental and emotional requirements for fire | |||
brigade members. l | |||
! | |||
; | |||
! | |||
1 | |||
7 | |||
. ..- . -. .. - - - | |||
,- . . - , . . - - .- - | |||
. - - - - | |||
. | |||
. | |||
.- | |||
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: | |||
' | |||
(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 | |||
' | |||
trained in the use of hose lines prior to becoming a brigade i | |||
' | |||
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. | |||
! | |||
) (6) High pressure hose lines that exist in the plant deviate from | |||
' | |||
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. | |||
> | |||
8 | |||
, | |||
- - - - - , - | |||
, - , , , - ,n, , | |||
n ,-, | |||
- | |||
.- | |||
(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. | |||
9 | |||
. . | |||
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. | |||
10 | |||
l | |||
. . . . . - -. ~ . - , -~ _ . . , - . .- | |||
. | |||
. . , | |||
, | |||
I | |||
! | |||
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 | |||
~ | |||
* | |||
: 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 ' | |||
7 | |||
as a thorough knowledge of the plant, prccedures, and regulatory and | |||
. | |||
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. | |||
) | |||
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. | |||
f | |||
> | |||
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 | |||
1 | |||
licensee's fire protection program. As a result of-the review, it was- | |||
: | |||
, 11 | |||
- | |||
_ -_ _ __ _ _ . _ _. - .__ . - . _ - _ . ._ _ _,_ | |||
,- .- | |||
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, | |||
12 | |||
.. - - . ,.-_ -_. | |||
. . | |||
, | |||
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 | |||
l. ! | |||
l | |||
i 13 | |||
! | |||
' | |||
1 | |||
- | |||
.. - - .- .. | |||
- - -. - | |||
! | |||
.- .. | |||
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. | |||
: 14 | |||
__ | |||
, _ _ , _ _ | |||
. _ _ _ . . _ __ _ _ | |||
. . _ _ | |||
.- .. . - . - .. . . .. - - | |||
4 O | |||
' 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. | |||
' | |||
(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. | |||
15 | |||
i | |||
._ | |||
. . | |||
, | |||
(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 | |||
' | |||
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: | |||
1 | |||
16 | |||
.- . - , - ..- . . . . .-_ . .. . . .- - | |||
. . | |||
. | |||
,. .. | |||
(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). | |||
! | |||
! (4) CECO Fire Protection Engineer | |||
i | |||
The ensite responsibilities are assigned to: | |||
: | |||
(1) Fire Commissioner - Station Manager , | |||
, | |||
] (2) Fire Marshall | |||
I | |||
(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 | |||
' | |||
The inspectors reviewed the following technical specification * | |||
' | |||
su'veillances: , | |||
, Technical Description of Procedure | |||
Specification Surveillance Number | |||
4.7.5.1.1.a Valve lineup LOS-FP-M3, Rev. 7 | |||
l | |||
' | |||
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. | |||
, | |||
' | |||
17 : | |||
'l | |||
- _ _ - _ _ - - _ _ _ _ _ _ _ _ _ _ - - _ _ _ - _ _ _ - _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ - _ - _ _ _ - - - ._ | |||
- - - | |||
.. .~ | |||
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 | |||
18 | |||
. . . - -. . .. - . - . . , - .. . - - - - _ | |||
.- t+ | |||
: | |||
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)). | |||
, | |||
Oppli_ty Assurance Program | |||
i | |||
3 | |||
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. | |||
' | |||
J | |||
, (2) Audit Checklist and Record Sheet 01-BS-1, March 19-22,1985, | |||
; and 01-BS-11, September 10-13, 1985. ! | |||
. | |||
(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. | |||
^ | |||
1 | |||
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 | |||
' | |||
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 | |||
' | |||
were discussed with the licensee. | |||
., | |||
* | |||
4 | |||
. | |||
} | |||
! | |||
19 | |||
: | |||
-, , . . . . .. - . - - . - . . - . - .- . ~ .. - . - . . - - . . . - - . - . - ~ . . - | |||
}} |
Latest revision as of 00:12, 18 December 2020
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: |
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
Text
- _ - .
'
,' .
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
i
Chicago IL 60690
- Facility Name
- LaSalle
Inspection At: LaSalle Nuclear Power Station, Marseilles, Illinois
Inspection Conducted: Jan ry 13-27, 6
Inspectors: .
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Date
C. Ramsey ENh Date
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/
. Holmes '
Mb
'Date
I. N N~
Z. Falevitz 2/27Mt
.Date
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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
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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.
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(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).
!
! (4) CECO Fire Protection Engineer
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The ensite responsibilities are assigned to:
(1) Fire Commissioner - Station Manager ,
,
] (2) Fire Marshall
I
(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
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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4.7.5.1.3.a.2 Pilot Cell LOS-DC-W1, Rev. 9
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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.- t+
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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3
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
'
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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