IR 05000321/1987030

Insp Repts 50-321/87-30 & 50-366/87-30 on 871116-20. Violations Noted.Major Areas Inspected:Fire Protection/ Prevention & Followup on Previously Identified Insp Items

ML20237E345
Person / Time
Site:	Hatch
Issue date:	12/16/1987
From:	Conlon T, Wiseman G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20237E304	List: IR 05000321/1987030 ML20237E303 ML20237E330
References
50-321-87-30, 50-366-87-30, NUDOCS 8712280282
Download: ML20237E345 (14)

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UNITED STATES cje Rf ouq

NUCLEAR REGULATORY COMMISSION

[ <E REGION 11 -

g j 101 MARIETTA STREET. * 's ATLANTA, GEORGI A 30323

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Report Nos.: 50-321/87-30 and 50-366/87-30 Licensee: Georgia Power Company P. O. Box 4545 Atlanta, GA 30302 Docket Nos.: 50-321 and 50-366 License Nos.: DPR-57 and NPF-5 Facility Name: Hatch 1 and 2 Inspection Conducted: November 16-20, 1987 Inspector:

G. R. Wiseman k. A e /445M7 Da'te Signed Accompanying Personn : D. C. Ward Approved #7'T /E 4 7 1. E. Conlon, Plant Systems Section chief Date 51gned Division of Reactor Safety

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SUMMARY Scope: This routine, unannounced inspection was in the areas of fire protection / prevention and followup on previously identified inspection item Results: Two violations were identified: Failure to Implement Fire Protection Program Procedures for Documentation of Fire Protection' Activities, paragraph 5.f.(2) and Failure to Repeat Unsatisfactory Fire Brigade Drills withinRequiredTimePeriod, paragraph 5.f.(2).

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REPORT DETAILS Persons Contacted Licensee Employees

• L. Adams, Superintendent, Nuclear Security

• G. Barker, Superintendent, I&C

• J. Bennett, Superintendent, Plant Training

• R. Bunt, Project Manager, Appendix R

• L. Byrnes, Senior Nuclear Engineer

• C. Coggen, Manager, Training and EP

• G. Creighton, Regulatory Specialist /NSC

• 0. Fraser, QA Site Manager

• G. Goode, Superintendent, General Engineering Support

• C. Goodman, ISEG Engineer-

• R. Hayes, Acting Manager, Operations

• D. McAfee, Fire Protection Supervisor

• C. McDaniel, Acting Manager, General Support

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• C. Moore, Senior Method and Training Specialist l *J. Newton Outages and Planning

• Nix,PlantManager l *T. Powers, Manager, Engineering i

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• D. Smith, HP Support

• E. Sorrell, Document Control Supervisor

• E. Stewart, QA Field

• S. Tipps, NSAC Manager Other licensee employees contacted included construction craftsmen, engineers, technicians, oparators, mechanics, security force members, and office personnel.

l NRC Resident Inspectors

i *P. Holmes-Ray

! *J. Menning l *R. Musser

• Attended exit interview Exit Interview The inspection scope and findings were summarized on November 20, 1987, with those persons indicated in paragraph 1 above. The inspector described the areas inspected and discussed in detail the inspection findings. No dissenting comments were received from the licensee. The following new items were identified during this inspection:

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' Unresolved Item (321, 366/87-30-01) -. Incomplete Evaluations of Fire Protection Program Quality Assurance Audit Items - paragraph , Violation Item (321,366/87-30-02)- Failure to Implement Fire l Protection Program Procedures for Documentation of Fire Protection Activities - paragraph 5.f.(2). Violation Item (321, 366/87-30-03) - Failure to Repeat Unsatisfactory Fire Brigade Drills within Required Time Period - paragraph 5.f.(2). Inspector Followup Item (321, 366/87-30-04) - Additional Fire Brigade Training and Drills Required - paragraph 5.f.(3). Inspector Followup Item (321, 366/87-30-05) - Justification for C0 2 Extinguisher Mountings in the Control Room - paragraph 5.g.(2).

During the course of the exit, the licensee stated there will be increased emphasis on fire brigade training and drills in response to Inspector Followup Item 321, 366/87-30-04.

l The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspectio . Licensee Action on Previous Enforcement Matters This subject was not addressed in the inspectio j

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4. Unresolved Items Unresolved items are matters about which more information is required to j

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determine whether they are acceptable or may involve . violations or  !

deviations. One unresolved item identified during this. inspection is

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discussed in paragraph I i 5. Fire Protection / Prevention Program (64704)

l l Fire Prevention / Administrative Control Procedures

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The inspector reviewed the following Fire Prevention / Administrative procedures:

l Procedure N Title 10AC-MGR-001-0S, Revision 2, - Plant Organization, Staff dated 2/15/86 Responsibilities and Authorities 10AC-MGR-003-0S, Revision 5, - Preparation and Control of

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dated 9/26/86 Procedures

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Procedure N Title (cont'd)

10AC-MGR-006-05, Revision 1, -

Emergency Plans dated 9/1/85 10AC-MGR-007-05, Revision 1, -

PersonnefQualifications dated 8/1/86 Requirements 20AC-ADM-001-05, Revision 2, -

Document Distribution and dated 4/1/87 Control 20AC-ADM-002-05, Revision 2, -

Plant Records Management dated 4/15/87 40AC-ENG-008-05, Revision 0, -

Fire Protection Program dated 4/6/87 41FP-FPX01-0, Revision 0, -

Drill Planning, Critiques and dated 6/29/84 Training Documentation The inspector reviewed the licensee's weekly inspection results records for 1987 as required by Procedure 40AC-ENG-008-0S (Attach -

ment 1). The records reviewed were found in the possession of the Engineering Fire Protection Group, and had not yet been forwarded to Document Control as required by Section 8.1.1.8 of 40AC-ENG-008-05, Fire Protection Program. The inspectors expressed concern that these records may become lost unless timely submittal to Document Control is accomplished. This will be reviewed during a future NRC inspec-tio Other than noted, it appears that the above procedures meet the NRC guidelines of the document entitled " Nuclear Plant Fire Protection-unctional Responsibilities, Administrative Control, and Quality Assurance" dated June 197 b. Fire Protection Surveillance Procedures The inspector reviewed the following Fire Protection System Surveillance Procedures:

Procedure N Title 42SV-FPX-003-05 (Rev. 2) - Emergency Light Surveillance 42SV-FPX-008-05 (Rev. 0) - Fire Protection Water Suppression System Flow Test

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42SV-FPX-016-25 (Rev. 1) - Sprinkler System Surveillance Safety-Related Areas 42SV-FPX-018-2S (Rev. 0) - Fire Barrier 18 Month Surveillance 42SV-FPX-019-25 (Rev. 0) - Penetration Seal Surveillance 42SV-FPX-022-05 (Rev. 0) - Fire Protection Hydrant House Inspection 42SV-FPX-031-0N (Rev. 0) - Fire Fighting Equipment Surveillance 42SV-SUV-015-2S (Rev. 5) - Fire Detector Surveillance - Safety-Related Areas 42SV-SUV-016-IS (Rev. 2) - Fire Protection Valve Cycling Surveillance l

42SV-SUV-011-15 (Rev. 0) - Monthly Alarm Checks l The above surveillance procedures were reviewed to determine if the various test outlines and inspection instructions adequately implement the surveillance requirements of Appendix 8 of the plant Fire Hazards Analysis. In addition, these procedures were reviewed to determine if the inspection and test instructions followed general industry fire protection practices, NRC fire

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guidelines and the guidelines of the Nationa' arotection program Fire Protection

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Association (NFPA) Fire Code Based on this review, it appears that the above procedures are satisfactor Procedure 42SV-FPX-007-05, Cable Tray Surveillance Fire Protection Material, was in the verification process at the time of the I inspection and was not available for review. The initial run of this surveillance is scheduled for 1988. The procedure and results from this surveillance will be reviewed in a future inspection, c. Fire Protection System Surveillance Inspection and Tests The inspector reviewed the following surveillance inspection and test records for'the dates indicated:

Procedure N Test Results Reviewe_d 42SV-FPX-003-0S -

Monthly for 1987 42SV-FPX-022-0S -

Monthly for 1987 42SV-SUV-011-15 -

Monthly for 1986 l

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The surveillance test record data and testing frequency associated with the above fire protection system surveillance test / inspections were found to be satisfactory with regard to meeting the requirements -

of the plant's Fire Hazards Analysis, Appendix d. Fire Reports The inspectors reviewed the station's fire reports for 1984, 1985, 1986, and 1987. These reports are. designated in Fire Protection Procedure AG-FPX-01-01. These reports indicated that there were-eight incidents of fire in 1984, two fire events in 1985 three events in 1986, and only one event so far in 1987. Of. tbe fire events reviewed, approximately one-half of the events involved I equipment failures and the remainder. involved welding or cutting activities. None of the fire events reviewed appeared to be of major-safety significanc e. Fire Protection Audit The most recent audit reports of the Hatch Fire Protection Program were reviewe These audits were:

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Professional Loss Control (PLC) Report 87-FP-1 (Three . Year Independent Audit) July 27-31, 1987

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Nuclear Mutual Limited NML Property Inspection - October 5-9, 1987

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Fire Protection Annual Audit,. Southern Company ' Services -

August 10-12, and 25, 1983-These audits identified several fire protection program discrepancies and unresolved items, and recommended several program improvement The inspectors reviewed the Corrective Action Tracking Forms for QA Item Numbers QA-83-5 and -4. These items identify discrepancies in the fire pumps installation relative to the requirements of National Fire Protection Association (NFPA) Standard 20. The licensee's evaluation accepts these NFPA code discrepancies as not affecting the operability of the fire pumps, but states that it may cause a second fire pump to start sooner with the existing design than with the NFPA standard design. The inspectors expressed concern that the existing design may be contributing to the fire main piping ruptures that the plant has experienced over the years. A review of the Special Reports associated with the pipe rupture events indicated that most events involved the simultaneous starts of the electric and No. I diesel fire pumps.

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These situations were not included in the licensee's evaluations for closure of the QA concern items; therefore, this is identified as Unresolved Item 361, 366/87-30-01, Incomplete Evaluations of Fire Protection Program Quality Assurance Audit Items. This item will be reviewed during a subsequent NRC inspectio The licensee has either implemented the corrective actions associated with other audit findings or a scheduled date for completion of the corrective actions had been established. Except as noted above, the licensee appears to be taking the appropriate corrective actions on audit finding Fire Brigade (1) Organization The total station fire brigade is composed of approximately 66 personnel from the operations staff. The on duty. shift fire brigade leader is normally the Unit 2 Shift Supervisor and the remaining four fire brigade members are composed of plant equipment operator The inspectors verified that sufficient aersonnel were assigned to each shift to meet the minimum fire arigade staff requirements of the Fire Protection Progra Therefore, it appears based on the review that there was sufficient manpower on duty to meet the fire brigade require-ments of the plant's Fire Protection Progra (2) Training The inspector reviewed the training and drill records of four brigade leaders and six brigade members for 1986 and 198 The records reviewed indicated that each of these leaders and members attended the required training and participated in the required number of drill The inspector also verified that 'a fire brigade drill had been conducted yearly for each shift for 1986 and 1987. The review of the fire brigade drill critique Jackages for this period revealed that the required Fire Dril' and Critique Reports were not properly filled out. Section 7.2 of Procedure 41FP-FPX01-0, Drill Planning, Critiques and Training Documentation, requires a fire drill and critique report be comaleted by each reviewer during the performance of each dril' . Contrary to this requirement, of the six drill packages for 1986 and 1987 reviewed, only one Fire Drill and Critique Report was completed to the point. of signature and documenting the drill as L_--_----_--___--___--___--__-_---.----.---- - - - - - - - - - - - - - - - - - - - - - - . . - - .

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" Satisfactory" or " Unsatisfactory". None of the drill packages had been transmitted to Document Control as required by Section 7.4 of Procedure 41FP-FPX01- All drill records reviewed were found in the possession of Engineering Fire Protection Grou In addition, Administrative Control Procedure 20AC-ADM-002-05, Plant Records Management, Section 8.3.5 requires that Document Control ensure that all required records have been received on a quarterly basis by comparing the log of received records to those identified as being required within that period in the Records Matrix. Based on the inspectors review and interviews

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! with Document Control personnel, it was determined that this document receipt verification was not accomplished for these Fire Protection Program documents. This is identified as Violation Item 321, 366/87-30-02, " Failure to Implement Fire Protection Program Procedures for Documentation of Fire Protection Activities".

Based upon the limited critique comments on the six drill packages reviewed, the inspector determined four drills were unsatisfactory. Section 8.2.3.4.5 of 40AC-ENG-008-05, " Fire Protection Program," and Section 8.2.5.4 of 40AC-FPX01-0 (deleted 4/6/87), Fire Protection Program, require unsatis-factory drills be repeated within 30 days., Contrary to this requirement, redrills were not conducted for any of the four unsatisfactory drill This is identified as Violation Item 321, 366 /87-30-03,Failure to Repeat Unsatisfactory Fire Brigade Orills within Required Time Perio In addition, the inspector reviewed the licensee's initial fire brigade training program to verify that the following training topics are being covered:

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Indoctrination of the plant fire fighting specific identification of each individual' plant with s responsi-bilitie Identification of the type and location of fire hazards and associated types of fires that could occur in the plan The toxic and corrosive characteristics of expected products of combustio Identification of the location of fire fighting equipment I for each fire area and familiarization with the layout of the plant, including access and egress routes to each area.

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The proper use of available fire fighting equipment and the correct method of fighting each type of fire. The types of fires should include fires in energized electrical equiptrent, fires in cable and cable trays, hydrogen fires, fires involving flammable and combustible liquids or hazardous process chemicals, fire resulting from construction or modifications (welding), and record file fire The proper use of communication, lighting, ventilation, and emergency breathing equipmen The proper method for fighting fires inside buildings and confined space The direction and coordination of the fire fighting activities (fire brigade leaders only).

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Detailed review of fire fighting strategies and procedure Review of the latest plant modifications and corresponding changes in fire fighting plan Based on this review, it appears that the licensee's initial fire brigade training program covers the above required training topics. In addition, it appears that the licensee's fire brigade training program repeats the basic fire fighting skills of the initial program to qualified fire brigade members every two year (3) Fire Brigade Drill During this inspection, the inspector witnessed an unannounced ;

fire brigade dril The drill fire scenario was a fire in the !

northeast corner of the Reactor Building 130' elevation which !

was apparently caused by a welding operation which ignited oily rags and scaffolding in the are Eight fire brigade members responded to the pending fire emergenc Five brigade members responded in full protective i turnout clothing and self-contained breathing epaaratus. The 1 remaining brigade members responded in protect 1ve turnout clothing onl The drill was terminated after approximately 35 i minutes due to unsatisfactory brigade performance. The drill ;

was considered unsatisfactory based on the following l observation.s: l

The brigade leader failed to respond with the fire preplan j for the are !

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The brigade leader failed to establish a command post with adequate communicatio The brigade leader did not perform a proper sizeup of the  ;

fire situation prior to initiating fire fighting activitie Health Physics did not respond to assist the brigad ,4

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Brigade response time was poo Brigade members did not utilize proper firefighting method Brigade members did not respead with self-contained breathing apparatus facemasks donne The inspector observed that over the past year, the brigade i performance has been steadily deteriorating as evidenced by this unsatisfactory drill and the unsatisfactory drills conducted during 1986 and 198 This indicates that further training and drills may be required to upgrade the quality of the brigade performance. This is identified as Inspector Followup Item 50-321, 366/87-30-04, Additional Fire Brigade Training and Drills Require g. Plant Tour and Inspection of Fire Protection Equipment

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(1) Outside Fire Protection Walkdown The inspector verified that the two water storage tanks  ;

contained sufficient water to meet the requirements of ;

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Appendix B of the Fire Hazards Analysis. The three fire pumas were inspected and found to be in service. The diese! fuel tanks for the diesel driven fire pumps contained approximately 400 gallons of fuel each which met the requirements of the Appendix B of the Fire Harzards Analysi The following sectional control valves in the outside fire protection water supply system and the low pressure C02 system ,

were inspected and verified to be properly aligned and locked in '

position: '

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Valve N Descrip_ tion .

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^Y43-F306E hnt Loop Tie In Isolation D

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Y43-F306F Firt Pump Cross Tie Isolation 1

Y43-930G)- \ East Loop Tie In Iso;ation X Y43-F309P Service Buildins Isolation Y43-F317B Y43-A.001A Tank I nir. tion

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Y43-F3170 Y43-F300B Tank Isolation

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! Y43-F318A ElecteIc Fire Pump Discharge"

'a Y43-F318D' 2A Diese7 Fire PumplHscharge

! ., Y43-F318E 2B Diesel Fire Pump Ofscharge CO2 Low Pressure Tank Isolation

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X43-F001 i \

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3 " Valve inoperable and under clearance

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s' ' The following fire hydrants and fire hydrant equipment houses

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[s Hy m nt/ Hose Hovse Number

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1Y43-F314A/2

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1Y43-F188/3

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, Y43-F314E/7 i 1Y43-F314F/8

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1Y43-F314G/9 '~t y/

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TheVuipmenthousescontainedtheminimumequipmentrequirement '

i of that specifikt b a-

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' Thef t AppcrtenPbs,yand/or NFPA-24,the FSAR Private Fire Service commitment Mains and The equipment l ?

,. appeared to be' adequately maintaine . .s ,

e A tour ofithe exterior of the plant indicated that sufficient .;

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i 'r.learance3 was provided between permenent safety-related

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, ,,. So0l1 dings and structures and temporary buildings, trailtrs, and [ other transient combustible materials. The general housekeeping of the areas adjacent to the permanent plant structores was

., satisf actor (2) Permanent Plant Fire Protection Features '

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s'A plant tour was made by.the inspecto During the plant tour,

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the following safe shutdown related plant areas and their l elat'eri fire protection featurey. vere inspected: l

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Fire Area Description

0501 River Intake Structure 0014K Corridor 130' Elevation Control Building 0024A Unit 1/ Unit 2 Cable Spreading Room Control Building 147' Elevation ,

2016 'd 600V, Switchgear Room 2C Control T(uilding 130' Elavatica 2018 W DC SWGR Room 2A Control Building IST Elevation

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1203F Unit 2 Reactor 130' Elevation 0024C Control Room Unit I and 2 Concrd Building 164' Elevation .

The fire / smoke detection systems, manual fire fighting equipment (i.e., portable extinguishers, ho?e stations, etc.) and the fire

! area boundary walls, floors and e dling associated'for the above plant areas were inspected and wrified to be in service or functional. The inspector noted during his tour of the control

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room that C0 2 extinguishers are not securely mounte The potential exists for the high pressure C0g cylinder to. be knocked or f all from its stand and become a missile in the ,

Control Roo The inspector requested documentation proving'7.he extinguisher mounting was acceptable from a safety and seismic standpoint. This information war, not available. Therefore, this ir McMified as Inspectcr Followup Item 50-321, 366/87-Jr 0+ Justification for CO2 Extinguisher Mountings in the Control Roo The automatic sprinkler systems initalled in Fire Areas 0014K, 0024A, 1203F, and 2104 were inspected 3rd fcund to.be inservic l Based on this inspection, it appears that the fire prctection features associated with the above plant .dreas'are satisfac-torily maintaine i The plant tour also verified the licensee's implementation of the fire prevention administrative procedures. The control of combustibles and flammable materials, liquids and gases, and the general housekeeping were found to l'e satisfactory in th,e areas

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(3) Appendix R Fire Protection Features The inspector visually inspected the fire rated raceway fire barriers required for compliance with Appendix R,Section III.G.2 in the following plant areas:

Fire Area Description 0014K Corridor 130' Elevation Control Building 0501 River Intake Structure 1203F Unit 1 Reactor Building 130' Elevation Based on the inspector's observations of the above raceway fire barrier enclosures, it appears that the one hour fire barrier integrity associated with the above assemblies were being properly maintained in a satisfactory conditio The inspector made a walkdown of the Appendix R related sprinkler protection in the following plant areas:

Fire Area Description 0014K Corridor 130' Elevation Control Building 1203F Unit 1 Reactor Building 130' Elevation Based on this walkdown, the inspector determined that the sprinkler protection provided for the areas identified above provided sufficient protection with respect to controlling an exposure fir The following eight-hour emergency lighting units were inspected:  ;

Unit N Location i

1R42-E001 Control Building Stairwell  !

1R42-E021 Reactor Building 130'

1R42-E049 Reactor Building 130'

1R42-E123 Control Building 130'

2R42-E016 Control Building 130'

2R42-E105 Control Building 130'

2R42-E106 Control Building 130'

2R42-E112 Control Building 130'

These units were in service, lamps were properly aligned and appeared to be properly maintaine Except as noted above, within the areas inspected, no additional violations or deviations were identifie __ _ _ _ _ _ _ _ _ _ .

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i 6. Inspector Followup Items (Closed) Inspector Followup Item (IFI) 321, 366/86-27-01, Fire Protection Administrative Control Procedural Weakness in the Areas of Bulk Gas Storage, Fire Brigade Drills, and Fire Brigade Instructor Qualifications:

During this inspection, the Fire Protection Program Procedure 40AC-ENG-008-05 (formerly 40AC-FPX01-0) was reviewe The renumbered and revised procedure now specifies in (Section 8.1.3) criteria for bulk storage of materials. Sections 8.2.5 and 5.1.5 now address fire brigade drill frequency and fire brigade instructor state l certification. These revisions are adequate to resolve the admin-istrative procedural concerns; therefore, this item is close (Closed) IFI 321, 366/86-27-03, Failure of the Underground Fire Water Distribution System to Provide Redundant Fire Water Supply to the Unit 1 Reactor Building:

During this inspection, the inspector reviewed Maintenance Work Order (MWG) 1-86-8770 which was issued on October 6,1986. This MWO repaired the leak in the 14-inch underground and the main was returned-to service was indicated by Quality Control signoff the MWO on December 30, 198 This action closes this item, (Closed) IFI 321, 366/86-27-04, Degraded Fire Doors Installed in Proposed Appendix R Fire 8arriers:

The licensee issued Deficiency Report (DR) 2-86-660 which indicated that doors IL48-C3 and C-22 were inoperable. Appropriate fire l

i watches doors were were stationed repaired and by/or replaced.the licensee Door IL48-03 wasduring the period in wh replaced under Maintenance Work Order 1-86-7964 and ,7965 and 1-85-425 Door 1L48-C22 was repaired under M0W 1-86-796 Reviews of the MW0s indicated that the work was completed for these doors December 10, 1986. Based on this review, this item is considered close (Closed) IFI 366/86-27-05, Unit 2 East Cableway Sprinkler System Obstructions Hinder the System's Ability to Control an Exposure Type Fire:

The inspectors reviewed DCR 85-252, and MWO 2-86-345 These indicate that the sprinkler heads between column line T14 and T16 of the Unit 2 east cableway were relocated to clear any obstruction The work associated with the design change was completed on November 12, 198 During the plant walkthrough 'during this inspection, these areas were reviewed and the sprinkler appeared acceptable. Based on this review, this item is considered close _ _ _ _ _ .-- __-________ _