IR 05000254/2006002

IR 05000254-06-002 (Drs), 05000265-06-002 (Drs); 04/24/06 - 05/12/06; Quad Cities Nuclear Power Station (Qcnps), Units 1 and 2; Triennial Fire Protection Baseline Inspection

ML062140118
Person / Time
Site:	Quad Cities
Issue date:	07/31/2006
From:	Lara J F Engineering Branch 3
To:	Crane C M Exelon Generation Co, Exelon Nuclear
References
IR-06-002
Preceding documents:	ML071590365 (5 June 2007)
Download: ML062140118 (42)

Text

July 31, 2006

Mr. Christopher M. CranePresident and Chief Nuclear Officer Exelon Nuclear Exelon Generation Company, LLC Quad Cities Nuclear Power Station 4300 Winfield Road Warrenville, IL 60555

SUBJECT: QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2NRC TRIENNIAL FIRE PROTECTION BASELINE INSPECTIONINSPECTION REPORT 05000254/2006002(DRS); 05000265/2006002(DRS)

Dear Mr. Crane:

On May 12, 2006, the U.S. Nuclear Regulatory Commission (NRC) completed a triennial fireprotection baseline inspection at your Quad Cities Nuclear Power Station, Units 1 and 2. Theenclosed inspection report documents the inspection results, which were discussed at the end of the on-site activities on May 12, 2006, and during a re-exit meeting held by telephone at the conclusion of the inspection on June 29, 2006, with Mr. T. Tulon and other members of your staff.The inspection examined activities conducted under your license, as they relate to safety and tocompliance with the Commission's rules and regulations, and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.Based on the results of this inspection, six NRC-identified findings of very low safetysignificance, all of which involved violations of NRC requirements were identified. However,because these violations were of very low safety significance, and because the findings were entered into the licensee's corrective action program, the NRC is treating these findings as Non-Cited Violations in accordance with Section VI.A.1 of the NRC's Enforcement Policy. Additionally, two licensee identified violations are listed in Section 4OA7 of this report.If you contest the subject or severity of a Non-Cited Violation, you should provide a responsewithin 30 days of the date of this inspection report, with the basis for your denial, to the U. S.

Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with a copy to the Regional Administrator, U. S. Nuclear Regulatory Commission -

Region III, 2443 Warrenville Road, Suite 210, Lisle, IL 60532-4352; the Director, Office ofEnforcement, U. S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the Resident Inspector Office at the Quad Cities Nuclear Power Station facility.

C. Crane-2-In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter,its enclosure, and your response (if any), will be available electronically for public inspection inthe NRC Public Document Room or from the Publicly Available Records (PARS) com ponent ofNRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,/RA/Julio F. Lara, ChiefEngineering Branch 3 Division of Reactor SafetyDocket Nos. 50-254; 50-265License Nos. DPR-29; DPR-30

Enclosure:

Inspection Report 05000254/2006002(DRS); 05000265/2006002(DRS)

w/Attachment:

Supplemental Informationcc w/encl:Site Vice President - Quad Cities Nuclear Power StationPlant Manager - Quad Cities Nuclear Power Station Regulatory Assurance Manager - Quad Cities Nuclear Power Station Chief Operating Officer Senior Vice President - Nuclear Services Senior Vice President - Mid-West Regional Operating Group Vice President - Mid-West Operations Support Vice President - Licensing and Regulatory Affairs Director Licensing - Mid-West Regional Operating Group Manager Licensing - Dresden and Quad Cities Senior Counsel, Nuclear, Mid-West Regional Operating Group Document Control Desk - Licensing Vice President - Law and Regulatory Affairs Mid American Energy Company Assistant Attorney General Illinois Emergency Management Agency State Liaison Officer, State of Illinois State Liaison Officer, State of Iowa Chairman, Illinois Commerce Commission D. Tubbs, Manager of Nuclear MidAmerican Energy Company

SUMMARY OF FINDINGS

IR 05000254/2006002(DRS), 05000265/2006002(DRS); 04/24/06 - 05/12/06; Quad CitiesNuclear Power Station (QCNPS), Units 1 and 2; Triennial Fire Protection Baseline Inspection.This report covers an announced triennial fire protection baseline inspection. The inspectionwas conducted by Region III inspectors. Based on the results of this inspection, six Greenfindings associated with six non-cited violations were identified. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, "Significance Determination Process" (SDP). Findings for which the SDP does not apply may be "Green" or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors isdescribed in NUREG-1649, "Reactor Oversight Process," Revision 3, dated July 2000.A.Inspector-Identified and Self-Revealed Findings

Cornerstone: Mitigating Systems

Green.

The inspectors identified a Non-Cited Violation (NCV) of 10 CFR Part 50,Appendix R, Section III.G.2, having very low safety significance (Green) involving thelicensee's failure to ensure, in the event of a severe fire, that one redundant train of systems necessary to achieve and maintain hot shutdown conditions was free of firedamage. Specifically, the licensee failed to ensure, in the event of a fire in any of the III.G.2 fire areas, that one redundant train of reactor coolant inventory makeup water remained free of fire damage. Instead the licensee credited the dedicated safe shutdown makeup pump (SSMP) for reactor coolant inventory makeup water in the III.G.2 fire areas. This finding was entered into the licensee's corrective action programas Issue Report (IR) 00502702, "NRC Inspection Finding Concerning App R R edundantTrains," dated June 22, 2006. The licensee plan to review the options for resolving this issue, and pursue the appropriate resolution.The finding was more than minor because this failure could have affected the mitigatingsystems cornerstone objective and safe shutdown (SSD). Specifically, the licenseefailed to ensure one redundant train of reactor coolant inventory makeup water was available, and instead relied on an alternate shutdown system wit hout an anal yses andprocedures that demonstrated full compliance with all of the requirements of 10 CFR Part 50, Appendix R, Section III.G.3, and Section III.L, or requesting prior NRCapproval. The finding was not suitable for SDP evaluation, but has been reviewed by

NRC management and was determined to be a finding of very low safety significance.(Section 1R05.1b.1)*Green. The inspectors identified a NCV of 10 CFR Part 50, Appendix R, Section III.G.2,having very low safety significance (Green) involving the licensee failure to ensure, in the event of a severe fire, that one redundant train of systems necessary to achieve andmaintain hot shutdown conditions was free of fire damage. Specifically, the licensee failed to ensure, in the event of a fire in Fire Areas TB-III, 13-1 or 24-1, that one redundant train of residual heat removal service water (RHRSW) remained free of firedamage. Instead the opposite unit's RHRSW train was cross-tied (i.e., an alternativeSSD activity) and credited for torus cooling during hot shutdown for a III.G.2 fire area.

2In addition, the licensee failed to have an analyses and procedures that demonstratedfull compliance with all of the requirements of 10 CFR Part 50, Appendix R,

Section III.G.3, and Section III.L. This finding was entered into the licensee's correctiveaction program as IR 00502702, "NRC Inspection Finding Concerning Appendix RRedundant Trains," dated June 22, 2006. The licensee plan to review the options for resolving this issue, and pursue the appropriate resolution.The finding was more than minor because the failure to ensure one redundant train ofRHRSW was available for torus cooling for hot shutdown could have affected the mitigating systems cornerstone objective and SSD. The finding was not suitable forSDP evaluation, but has been reviewed by NRC management and was determined to bea finding of very low safety significance. (Section 1R05.1b.2)*Green. The inspectors identified a NCV of 10 CFR Part 50, Appendix B, Criterion V,"Instruction, Procedures, and Drawings," having very low safety significance (Green)involving inadequate procedure steps. Specifically, The licensee failed to provide adequate procedure steps in-accordance with Appendix R requirements for hot shutdown and allowed the replacement (i.e., a repair) of breaker fuses prior to attaining hot shutdown. Specifically, QCNPS's Procedure QOP 6500-10 "Local Control of 4160 and 480 Volt Motor Operated Circuit Breaker," Revision 8, included a hot shutdown repair to replace any circuit breaker's control fuses that were believed to be blown due to a fire-induced failure. This fuse replacement constituted a hot shutdown repair which was not allowed by 10 CFR Part 50, Appendix R. Once identified, the licensee revised procedure QOP 6500-10 and added steps to manually close breakers using a local pushbutton. This finding was entered into the licensee's corrective action program as IR 00485702, "Required SSDA Actions Not Contained in QCARP 0030-01," dated May 2, 2006. The licensee revised procedure QOP 6500-10.The finding was more than minor because the failure to include adequate proceduresteps could have affected the mitigating systems cornerstone objective and SSD. Performing the repair activities could have delayed and/or complicated shutdown of the plant. The finding was of very low safety significance because the licensee could have manually charged the breaker's spring and closed the breaker using the pushbutton located at the breaker. (Section 1R05.5b.1)*Green. The inspectors identified a NCV of QCNPS's license condition for fire protection,having very low safety significance (Green) involving the lack of complete and accurate information in the QCNPS's fire pre-plans for various plant fire areas. Specifically, the licensee failed to include important information in the fire pre-plans, such as hydrogen and electrical hazards, to assist the fire brigade to fight a fire within those plant fire areas. This finding was entered into the licensee's corrective action program as IR 00489175, "Quality of Fire Preplans (2006 FP Triennial)," dated May 11, 2006.The finding was more than minor because the failure to provide adequate warnings andguidance related to hydrogen and electrical hazards in the fire pre-plans could have adversely impacted the fire brigade's ability to fight a fire, thereby, increasing thelikelihood of a fire which would challenge SSD and could have affected the mitigating systems cornerstone objective. The inspectors determined that this issue also affectedthe cross-cutting area of Problem Identification and Resolution because the licensee 3failed to identify the presence of hydrogen and oxygen hazards in Fire Areas RB-7 andRB-19 during their review as part of the fire pre-plan improvement effort conducted as a result of previously identified corrective action (IR 00221528). The finding was of very low safety significance because of the extensive training provided to the fire brigade members to deal with unexpected contingencies. (Section 1R05.10b.1)*Green. The inspectors identified a NCV of QCNPS's license condition for fire protection,having very low safety significance (Green) involving adequacy of water pressure and flow rate at standpipes with hose connections. Specifically, the licensee failed to provide calculations to ensure that an adequate water pressure and flow rate were available to meet the QCNPS's FPP requirements. Once identified, the licenseeentered the finding into their corrective action program as IR 00489160, "Justification of Fire Hose Pressure and Flow Meeting NFPA," dated May 11, 2006, and planned to perform calculations to verify water flow at all affected standpipes with hose connections.The finding was more than minor because the failure to provide an adequate waterpressure and flow rate at standpipes with hose connections could hamper the fire brigades ability to fight a fire, thereby, increasing the likelihood of a fire which wouldchallenge SSD and could have affected the mitigating systems cornerstone objective. The finding was of very low safety significance because other defense-in-depth fire protection elements remained unaffected in all fire areas. (Section 1R05.10b.2)*Green. The inspectors identified a NCV of QCNPS's license condition for fire protection,having very low safety significance (Green) involving adequacy of number of Class A fire extinguishers. Specifically, the licensee failed to have an adequate number of Class A fire extinguishers available where significant fire hazards existed to meet the NFPA 10 Code requirements to suppress and/or extinguish Class A fire hazards. This finding was entered into the licensee's corrective action program as IR 00489426,

"Class A Fire Extinguisher Placement Improvements," dated May 12, 2006. The licensee planned to evaluate putting more Class A fire extinguishers into the plant.The finding was more than minor because failure to have an adequate number ofClass A fire extinguishers available could potentially escalate a small fire into a larger fire since only standpipes with hose connections were available and their use required a trained fire brigade to extinguish the fire. As a result, non-fire brigade personnel would be prevented from moving quickly to suppress and/or extinguish a small fire and the potential for an escalated fire could have affected the mitigating systems cornerstoneobjective. The finding was of very low safety significance because most fire areas and zones have fire detectors that would alarm in the control room and the fire brigade would respond to a fire in these areas. In addition, other defense-in-depth fire protection elements remained unaffected and a fire in these areas would not result in a loss of dedicated SSD systems. (Section 1R05.10b.3)

B.Licensee-Identified Violations

Two violations of very low safety significance, which were identified by the licensee,have been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensee's corrective action program. These violations and the licensee's corrective action tracking numbers are listed in Section 4OA7 of this report.

4

REPORT DETAILS

1.REACTOR SAFETYCornerstones: Initiating Events and Mitigating Systems1R05Fire Protection (71111.05T)The purpose of this inspection was to review the QCNPS's Fire Protection Program(FPP) for selected risk-significant fire areas. Emphasis was placed on determining that the post-fire safe shutdown (SSD) capability and the fire protection (FP) features weremaintained free of fire damage to ensure that at least one post-fire SSD success path was available. The inspection was performed in accordance with the Nuclear Regulatory Commission's (NRC's) regulatory oversight process using a risk-informedapproach for selecting the areas and attributes to be inspected. The inspectors with assistance from a senior reactor analyst used the QCNPS's Individual Plant Examination for External Events (IPEEE) to choose several risk-significant areas for detailed inspection and review. The inspectors' review of the following fire areas and/or zones represented completion of four samples for the triennial FP inspection:Fire AreaFire ZoneDescriptionTB-III8.2.6.AUnit 1 Turbine Building Ground Floor (South)

TB-III8.2.7.AUnit 1 Turbine Building Mezzanine Floor (South)13-18.2.8.BUnit 1 4-kV Bus 13-1 Switchgear Area (North)24-18.2.8.CUnit 2 4-kV Bus 24-1 Switchgear Area (South)For each of the selected fire areas and/or fire zones, the inspectors focused on the fireprotection features, the systems and equipment necessary to achieve and maintain safeshutdown conditions, determination of licensee commitments, changes to the FPP, and evaluated the licensee's FPP against applicable NRC requirements..1Systems Required to Achieve and Maintain Post-Fire SSDTitle 10 of the Code of Federal Regulations (CFR), Part 50, Appendix R, Section III.G.1,required the licensee to provide FP features that were capable of limiting fire damage to structures, systems, and components (SSCs) important to SSD. The SSCs that werenecessary to achieve and maintain post-fire SSD were required to be protected by FP features that were capable of limiting fire damage to the SSCs so that:*one train of systems necessary to achieve and maintain hot shutdown conditionsfrom either the CR or emergency control station(s) was free of fire damage; and*systems necessary to achieve and maintain cold shutdown from either the CR oremergency control station(s) could be repaired within 72-hours.

5Specific design features for ensuring this capability were specified by 10 CFR Part 50,Appendix R, Section III.G.2.

a. Inspection Scope

The inspectors reviewed the plant systems required to achieve and maintain post-fireSSD to determine if the licensee had properly identified the components and systemsnecessary to achieve and maintain SSD conditions for each fire zone selected for review. Specifically, the review was performed to determine the adequacy of the systems selected for reactivity control, reactor coolant inventory makeup, reactor heatremoval, process monitoring, and support system functions. This review included theFP Safe Shutdown Analysis (SSA).The inspectors also reviewed the operators' ability to perform the necessary m anualactions for achieving SSD by reviewing procedures, the accessibility of SSD equipment,and the available time for performing the actions.The inspectors reviewed the QCNPS's Updated Final Safety Analysis Report (UFSAR)and the licensee's engineering and/or licensing justifications (e.g., NRC guidancedocuments, license amendments, technical specifications, safety evaluation reports (SERs), exemptions, and deviations) to determine the licensing basis.

b. Findings

b.1 Safe Shutdown Makeup PumpIntroduction: The inspectors identified a Non-Cited Violation (NCV) of 10 CFR Part 50,Appendix R, Section III.G.2, having very low safety significance (Green) involving thelicensee's failure to ensure, in the event of a severe fire, that one redundant train of systems necessary to achieve and maintain hot shutdown conditions was free of firedamage. Specifically, the licensee failed to ensure, in the event of a fire in any of the III.G.2 fire areas, that one redundant train of reactor coolant inventory makeup water remained free of fire damage. Instead, the licensee credited the dedicated safeshutdown makeup pump (SSMP) for reactor coolant inventory makeup water in these fire areas without having an analysis that demonstrated full compliance with all of the requirement of 10 CFR Part 50, Appendix R, Section III.G.3, III.L or requesting prior NRC approval.Description: During the inspectors' review of the licensee's Appendix R analysis for theselected fire zones, the inspectors identified that contrary to the NRC approved licensingbases, as discussed in the SER dated December 1981, the licensee was relying upon the SSMP as a redundant train for the reactor coolant inventory makeup in the event ofa severe fire in III.G.2 fire areas. Specifically, the SER dated December 1981, for the QCNPS, Section 2.2, "Areas Where Alternate Safe Shutdown Capability is Required,"stated ". . . for those areas where a fire results in loss of the RCIC system, the licenseehas proposed to provide a new safe shutdown makeup pump as an alternate."

Section 2.3, (Section III.G.2 of Appendix R), stated ". . . the licensee also indicated that all other areas of the plant not required to have an alternate safe shutdown system willcomply with the requirements of Section III.G.2 of Appendix R, unless an exemption 6request has been approved by the staff." Section 2.4, "Alternate Safe ShutdownSystem," stated ". . . the alternate safe shutdown system required for those areas notmeeting Section III.G.2 or included in the exemption requests consists of a new safe shutdown makeup pump and its associated support systems and instrumentation." Section 3.1.2, "Reactor Coolant Inventory," stated "The RCIC and shutdown makeuppump initially take suction from the CCST. Additional supply for the RCIC pump is provided by the suppression pool and for the makeup pump by the service water system." However, the NRC in April of 1988 revised Section 3.1.2 of this SER andstated that "Backup water supply source for the safe shutdown makeup pump will beprovided by the fire water system instead of the service water system as originallyindicated in the earlier SER Section 3.1.2." The inspectors could not find any otherdocuments from the NRC to the licensee indicating that the NRC had accepted the useof the SSMP as a redundant system for Appendix R.Prior to November 2000, the fire areas which were selected during this triennial FPinspection, TB-III, 13-1 and 24-1, were classified as alternate shutdown areas becauseof the potential fire damage to redundant RCIC system and the use of the alternateSSMP system. As a result of the FP Optimization Project at QCNPS, in November of 2000, the licensee completed safety evaluation SE-00-098. Part of the objectives of the optimization project were to reduce the number of the areas that require leaving the main control room and reduce reliance on 10 CFR Part 50, Appendix R exemptions. In order to accomplish these objectives, the licensee reclassified several fire areas from "Alternate" to "Redundant" by reclassifying the SSMP from "Dedicated" to "Redundant" per safety evaluation SE-00-098. The reclassification was based primarily on the functional equivalence between RCIC and SSMP. The licensee concluded that this change had no adverse impact on SSD and, therefore, did not require prior NRC approval. The licensee also modified the control for the SSMP system, where injectioncould be manually initiated from either the control room or remotely. This was changed from the initial installation of the pump. After the change, all of the circuitry needed to operate the SSMP was included in the SSA.In Generic Letter (GL) 86-10 "Implementation of Fire Protection Requirements," theNRC's response to Question 3.8.3 "Redundant Trains/Alternates Shutdown," stated, inpart, if the system is being used to provide its design function, it generally is consideredredundant. If the system is being used in lieu of the preferred system because theredundant components of the preferred system do not meet the separation criteria ofSection III.G.2, t he system is considered an alternate shutdown capability.The inspectors' review of SE-00-098 concluded that the licensee's basis for thereclassification was not appropriate, in that, based on the response to Question 3.8.3 in GL 86-10, and that the backup water supply source for the SSMP was from the fire water system, which was not a preferred source for reactor coolant inventory makeup water, the SSMP met the criteria for an alternate and not a r edundant system to RCIC. The licensee response was that based on General Electric (GE) Nuclear Energy (NE)document GE-NE-T43-00002-00-03-R01, "BWROG [Boiling Water Reactor OwnersGroup] Position on the Use of Safety Relief Valves and Low Pressure Systems as Redundant Safe Shutdown Paths," a system was considered to be "redundant" when itis used to provide its design function. The GE-NE document also indicated that based on the information provided in NRC GL 81-12, the BWROG sees no requirement or 7basis for limiting the systems that may be used as redundant SSD systems. Theinspectors reviewed the GE documents and could not find any justification in these documents that considered the use of the SSMP, with the FP system as a backup source, a redundant system for reactor coolant inventory makeup.In addition, Subsection 3 of Section III.L "Alternative and Dedicated ShutdownCapability" to 10 CFR Part 50 Appendix R required, in part, that the shutdown capabilityshall be independent of the specific fire area(s) and shall accommodate postfire conditions where offsite power is available and where offsite power is not available for 72-hours. Procedures shall be in effect to implement this capability. During theinspection, the licensee did not have analyses or procedures that satisfied these requirements. Instead, the licensee depended on offsite power supplied from the opposite unit equipment. Therefore, the inspectors also concluded that the change made by SE-00-098 was not appropriate and had adversely affected safe shutdown, because the licensee did not have the required analyses and procedures. The licensee entered this finding into the QCNPS's corrective action program as IR 00502702, "NRC Inspection Finding Concerning App R Redundant Trains," dated June 22, 2006. The licensee plan to review the options for resolving this issue and pursue the appropriate resolution.Analysis: The inspectors determined that failure to ensure that one redundant train ofsystems necessary to achieve and maintain hot shutdown conditions was free of firedamage resulted in a performance deficiency warranting a significance evaluation. The inspectors concluded that the finding was greater than minor in accordance with IMC 0612, "Power Reactor Inspection Reports," Appendix B, "Issue Screening," issued on September 30, 2005. The finding involved the attribute of protection against externalfactors (i.e., Fire) and could have affected the mitigating systems cornerstone objectiveof ensuring the availability, reliability, and capability of systems that respond to initiatingevents to prevent undesirable consequences (i.e., core damage). Specifically, the licensee's failure to ensure, in the event of a fire in any of the III.G.2 fire areas, that oneredundant train of reactor coolant inventory makeup water remained free of fire damage and instead credited the dedicated SSMP without demonstrating compliance with Appendix R, Sections III.G.3 and III.L, did not provide the adequate level of safetyrequired per Appendix R to ensure SSD capability.Since, the SSD path using the SSMP system did not meet the requirement ofAppendix R, Section III.G.2, but the SSD path was approved by the NRC as alternate,the inspectors determined that the finding was not suitable for SDP evaluation. Thefinding was reviewed by NRC management and was determined to be of very low safetysignificance (Green).Enforcement: 10 CFR Part 50.48, "Fire Protection," and 10 CFR Part 50, Appendix R,"Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1,1979," established specific FP features required to satisfy 10 CFR Part 50, Appendix A, General Design Criterion 3, "Fire Protection." Appendix R applies to licensed nuclear power electric generating stations that were operating prior to January 1, 1979, whichincluded QCNPS. Section III.G.2 of Appendix R to 10 CFR Part 50 required, in part,that where cables or the equipment of a redundant train of systems necessary toachieve and maintain hot shutdown conditions are located within the same fire area 8outside of primary containment, one of a specified means of ensuring that one of theredundant trains is free of fire damage shall be provided. Section III.G.3 of Appendix Rto 10 CFR Part 50 required, in part, that alternative of dedicated shutdown capabilityshould be provided where the protection of systems whose function is required for hotshutdown does not satisfy the requirement of paragraph III.G.2. Subsection 3 ofSection III.L. "Alternative and Dedicated Shutdown Capability" to 10 CFR Part 50,Appendix R required, in part, that the shutdown capability shall be independent of thespecific fire area(s) and shall accommodate postfire conditions where offsite power is available and where offsite power is not available for 72-hours. Procedures shall be in effect to implement this capability.Contrary to the above, in the event of a fire in any of these fire areas (TB-III, 13-1 or24-1), the licensee failed to ensure that one of the redundant trains of reactor coolant inventory makeup water remained free of fire damage. Instead, the licensee credited the use of the dedicated SSMP for reactor coolant inventory makeup without havinganalyses and procedures that demonstrated their full compliance with III.G.3 and III.L, or requesting prior NRC approval. Once identified, the licensee entered the finding intotheir corrective action program as IR 00502702, "NRC Inspection Finding ConcerningApp R Redundant Trains," dated June 22, 2006. Because this violation was of very low safety significance and it was entered into the licensee's corrective action program, this violation is being treated as a NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy (NCV 05000254/2006002-01(DRS);05000265/2006002-01(DRS)).

b.2 RHR Service Water Cross-tieIntroduction: The inspectors identified a NCV of 10 CFR Part 50, Appendix R,Section III.G.2, having very low safety significance (Green) involving the licensee's failure to ensure, in the event of a severe fire, that one redundant train of systemsnecessary to achieve and maintain hot shutdown conditions was free of fire damage.

Specifically, the licensee failed to ensure, in the event of a fire in any of these Fire Areas TB-III, 13-1 or 24-1 (III.G.2 Fire Area), that one redundant train of the residualheat removal service water (RHRSW) system remained free of fire damage. Instead thelicensee credited the cross-tie of the RHRSW train from the opposite unit for toruscooling during hot shutdown.Description: The RHRSW system at QCNPS for each unit, consisted of twoindependent and redundant subsystems (A Loop and B Loop). Each subsystem ismade of a header, two pumps, a suction source, valves, piping heat exchanger and associated instrumentation. Each loop provided cooling water flow to the respective loop of the RHR heat exchangers in the torus cooling and shutdown modes. The "A"subsystems for Unit 1 and Unit 2 could be connected by a normally locked, isolatedcross-tie line. Similarly, the "B" subsystems coul d be connected by another normallyisolated cross-tie line. These lines could be used to supply RHRSW from Unit 1 to Unit2 and vice-versa when required.The inspectors reviewed QCNPS's SSA which indicated that, in the event of a severefire in Fire Area 13-1, a redundant shutdown method and/or systems would be utilizedfor SSD of Unit 1. The analysis also indicated that, in the event of a fire in Fire Area 13-1, Unit 1 4KV Switchgear 13-1 (Division I) and/or both divisions of 480 V 9Switchgear (18 and 19) would be exposed. Division II of the Unit 1 RHR system wouldbe available for torus cooling and alternate shutdown cooling. However, the Unit 1 Division II RHRSW system was unavailable for a fire in Fire Area 13-1. This was due tothe 480V power feeds for the pump cubicle coolers being routed in this area. Therefore, the analysis stated that "Unit 1 RHRSW pumps may not be available for decay heatremoval. However, Unit 1 Division II RHRSW can be supplied by Unit 2 RHRSW Pumpvia a Division II mechanical cross-tie." The analysis also verified that cubical coolers for Unit 2, Division II RHRSW pumps were free of fire damage. The inspectors alsoidentified a similar issue in the event of a fire in Unit 2 Fire Area 24-1, in that the shutdown method for this area used the Unit 1 RHRSW to shutdown Unit 2.In addition, the inspectors noticed that the analysis also showed that, in the event of asevere fire in Fire Area TB-III, Division I of the RHR system would be available for toruscooling and alternate shutdown cooling. However, the AC power for RHR system wouldhave been provided from offsite power via the opposite unit (Unit 2 Bus 23) and cross-tied to Unit 1 Bus 13-1. Similarly, the analysis also indicated that the Unit 1 Division I RHRSW system may not be available for a fire in TB-III. This was due to the 4KVpower feeds for the pumps being routed in TB-III. Therefore, the analysis indicated thatUnit 1 RHRSW pumps may not be available for decay heat removal. However, theanalysis credited Unit 2 Division I RHRSW via a Division I mechanical crosstie valve.

Prior to November of 2000, Fire Areas TB-III, 13-1 and 24-1 were classified as analternate shutdown areas. As a result of the FP Optimization Project at QCNPS, the licensee reclassified these fire areas from "Alternate" to "Redundant" when they reclassifying the SSMP from "Dedicated" to "Redundant" per Safety Evaluation SE-00-098. However, the licensee failed to evaluate whether RHRSW cross-tie fromthe opposite unit met the requirement of 10 CFR Part 50, Appendix R, Section III.G.2.10 CFR Part 50.48 "Fire Protection" required, in part, that each operating nuclear powerplant must have a fire protection plan that satisfies Criterion 3 of appendix A of 10 CFR Part 50. 10 CFR Part 50, Appendix R establishes fire protection features required to satisfy Criterion 3 of appendix A with respect to certain generic issues for nuclear power plants licensed to operate before January 1, 1979. 10 CFR Part 50, Appendix R, also required, in part, that a fire protection program be established at each nuclear power plant. Section III.G.2 of Appendix R stated, in part, that where cables or equipment that could prevent operation or cause maloperation due to hot shorts, open circuits, or shorts to ground, of redundant trains of systems necessary to achieve and maintain hotshutdown conditions are located within the same fire area outside of primary containment, one of three means of ensuring that one of the redundant trains is free of fire damage shall be provided. The inspectors determined that the licensee's shutdownmethod in the event of a fire in any of these Fire Areas TB-III, 13-1 or 24-1, did not meetthe requirement of 10 CFR Part 50, Appendix R, Section III.G.2. Specifically, thelicensee's shutdown methods in Fire Areas TB-III, 13-1 and 24-1 which used theRHRSW system from the opposite unit instead of ensuring one of the redundant trainsof RHRSW from the respective unit with fire Unit 1 RHRSW was available. In addition,Subsection 3 of Section III.L "Alternative and Dedicated Shutdown Capability" to 10 CFRPart 50, Appendix R required, in part, that the shutdown capability shall be i ndependentof the specific fire area(s) and shall accommodate postfire conditions where offsite power is available and where offsite power is not available for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Procedures 10shall be in effect to implement this capability." During the inspection, the licensee didnot have analyses or procedures that satisfied these requirements for Appendix R III.L.The licensee justification was that Fire Areas TB-III,13-1 and 24-1 were alternateshutdown areas based on the reliance on SSMP and not due to the RHRSW cross-tie. The licensee also indicated that this method for SSD, which credited the RHRSWcross-tie, was previously communicated to the NRC staff by letter dated December 18, 1984. The inspectors reviewed the licensee's submittal and noticed that the RHRSWcross-tie was only credited in alternate shutdown fire areas.. Therefore, the inspectors concluded that the use of RHRSW cross-tie was only permitted for alternate shutdownareas (i.e., Section III.G.3), and would not meet the requirements of 10 CFR Part 50, Appendix R, Section III.G.2. See Section 1R05.1b.1 of this inspection report for furtherdiscussion of SSMP reclassification.Analysis: The inspectors determined that failure to ensure that one redundant train ofsystems necessary to achieve and maintain hot shutdown conditions was free of firedamage resulted in a performance deficiency warranting a significance evaluation. The inspectors concluded that the finding was greater than minor in accordance with IMC 0612, "Power Reactor Inspection Reports," Appendix B, "Issue Screening," issued on September 30, 2005. The finding involved the attribute of protection against externalfactors (i.e., Fire) and could have affected the mitigating systems cornerstone objectiveof ensuring the availability, reliability, and capability of systems that respond to initiatingevents to prevent undesirable consequences (i.e., core damage). Specifically, the licensee's failure to ensure, in the event of a fire in any of these Fire Areas TB-III, 13-1 or 24-1, that one redundant train of RHRSW remained free of fire damage and insteadcredited the RHRSW from the opposite unit, did not provide the adequate level of safetyrequired per Appendix R to ensure SSD capability.Since, the SSD path using the RHRSW system from the opposite unit did not meet therequirement of Appendix R, Section III.G.2, but it was credited in alternate shutdownareas at Quad Cities plant, the inspectors determined that the finding was not suitablefor SDP evaluation. The finding was reviewed by NRC management and wasdetermined to be of very low safety significance (Green).Enforcement: 10 CFR Part 50.48, "Fire Protection," and 10 CFR Part 50, Appendix R,"Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1,1979," establish specific FP features required to satisfy 10 CFR Part 50, Appendix A, General Design Criterion 3, "Fire Protection." Appendix R applies to licensed nuclear power electric generating stations that were operating prior to January 1, 1979, whichincludes QCNPS. Section III.G.2 of Appendix R to 10 CFR Part 50 required, in part, thatwhere cables or equipment of redundant trains of systems necessary to achieve andmaintain hot shutdown conditions are located within the same fire area outside of primary containment, one of a specified means of ensuring that one of the redundant trains is free of fire damage be provided.Contrary to the above, in the event of a fire in any of these Fire Areas TB-III, 13-1 or 24-1 (i.e., a III.G.2 area), the licensee failed to meet the requirement of Section III.G.2 of10 CFR Part 50, Appendix R. Specifically, in the event of a fire in any of these areas, the licensee credited the opposite Unit RHRSW system instead of ensuring one of the 11redundant trains of RHRSW from the respective unit with fire was available. Onceidentified, the licensee entered the finding into their corrective action program asIR 00502702, "NRC Inspection Finding Concerning App R Redundant Trains," datedJune 22, 2006. Because this violation was of very low safety significance and it was entered into the licensee's corrective action program, this violation is being treated as a NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy (NCV 05000254/2006002-02(DRS);05000265/2006002-02(DRS))..2Fire Protection of SSD CapabilityTitle 10 CFR Part 50, Appendix R, Section III.G.2, required separation of cables andequipment and associated circuits of redundant trains by a fire barrier having a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rating. If the requirements cannot be met, then alternative or dedicated shutdowncapability and its associated circuits, independent of cables, systems or components inthe area, room, or zone under consideration should be provided in accordance with 10 CFR Part 50, Appendix R, Section III.G.3.

a. Inspection Scope

For each of the selected fire areas, the inspectors reviewed the licensee's SafeShutdown Capability Analysis (SSCA) and Safe Shutdown Systems Analysis (SSSA) toensure that at least one post-fire SSD success path was available in the event of a fire.

This included a review of manual actions required to achieve and maintain hot shutdown conditions and make the necessary repairs to reach cold shutdown within 72-hours.

The inspectors also reviewed procedures to verify that adequate direction was provided to operators to perform these manual actions. Factors, such as, timing, access to the equipment, and the availability of procedures were considered in the review.The inspectors also eval uated the adequacy of fire suppressi on and detection systems,fire area barriers, penetration seals, and fire doors to ensure that at least one train of SSD equipment was free of fire damage. To accomplish this, the inspectors observed the material condition and configuration of the installed fire detection and suppression systems, fire barriers, and construction details and supporting fire tests for the installedfire barriers. In addition, the inspectors reviewed license documentation, such as, deviations, detector placement drawings, fire hose station drawings, carbon dioxide pre-operational test reports, smoke removal plans, fire hazard analysis reports, SSD analyses, and National Fire Protection Association (NFPA) codes to verify that the fire barrier installations met license commitments.

b. Findings

No findings of significance were identified..3Post-Fire SSD Circuit AnalysisTitle 10 CFR Part 50, Appendix R, Section III.G.1, required that SSCs important to SSDbe provided with FP features capable of limiting fire damage to ensure that one train of systems necessary to achieve and maintain hot shutdown conditions is free of firedamage. Options for providing this level of FP were delineated in 10 CFR Part 50, 12Appendix R, Section III.G.2. Where the protection of systems whose function wasrequired for hot shutdown did not satisfy 10 CFR Part 50, Appendix R, Section III.G.2,an alternative or dedicated shutdown capability and its associated circuits, was requiredto be provided that was independent of the cables, systems, and components in thearea. For such areas, 10 CFR Part 50, Appendix R, Section III.L.3, specifically requiredthe alternative or dedicated shutdown capability to be physically and electricallyindependent of the specific fire areas and capable of accommodating post-fire conditions where offsite power was available and where offsite power was not available for 72-hours.

a. Inspection Scope

On a sample basis, the inspectors evaluated the adequacy of separation provided forthe power and control cabling of redundant trains of shutdown equipment. This investigation focused on the cabling of selected components in systems important forSSD. The inspectors' review also included a sampling of components whose inadvertent operation due to fire may adversely affect post-fire SSD capability. Thepurpose of this review was to determine if a single exposure fire, in one of the fire areas selected for this inspection, could prevent the proper operation of both SSD trains.The inspectors evaluated selected portions of licensee's fuse/breaker coordinationanalysis for ground faults on the 4160 Volt alternating current (Vac) and 480Vac systems and the vital low-voltage ac and direct current

(dc) power sources to determinewhether fire-induced faults on distribution system cables or buses could degradepost-fire SSD capability. Specifically, the inspectors determined if selective coordinationexisted between branch circuit protective devices and the upstream distribution panel fuse/breaker feeders to ensure that in the event of a fire-induced short circuit, the fault would be isolated before the upstream feeder fuse/breaker tripped.

b. Findings

No findings of significance were identified..4Alternative SSD CapabilityTitle 10 CFR Part 50, Appendix R, Section III.G.1, required that SSCs important to SSDbe provided with FP features capable of limiting fire damage to ensure that one train of systems necessary to achieve and maintain hot shutdown conditions is free of firedamage. Options for providing this level of FP were delineated in 10 CFR Part 50, Appendix R, Section III.G.2. Where the protection of systems whose function wasrequired for hot shutdown did not satisfy 10 CFR Part 50, Appendix R, Section III.G.2,an alternative or dedicated shutdown capability independent of the area underconsideration was required to be provided. Additionally, alternative or dedicated shutdown capability must be able to achieve and maintain hot standby conditions andachieve cold shutdown conditions within 72-hours and maintain cold shutdown conditions thereafter. During the post-fire SSD, the reactor coolant process variables must remain within those predicted for a loss of normal alternating current power, and the fission product boundary integrity must not be affected (i.e., no fuel clad damage, rupture of any primary coolant boundary, or rupture of the containment boundary).

a. Inspection Scope

The inspectors reviewed the licensee's systems required to achieve alternative SSD todetermine if the licensee had properly identified the components and systems necessaryto achieve and maintain SSD conditions. The inspectors also focused on the adequacy of the systems to perform reactor pressure control, reactivity control, reactor coolantinventory makeup, decay heat removal, process monitori ng, and support systemfunctions.

b. Findings

No findings of significance were identified..5Operational Implementation of SSD CapabilityTitle 10 CFR Part 50, Appendix R, Section III.L.2.d, required that the process monitoringfunction should be capable of providing direct readings of the process variables necessary to perform and control the functions necessary to achieve reactivity control, reactor coolant inventory makeup, and decay heat removal.

a. Inspection Scope

The inspectors reviewed a sample of the actions defined in procedures QCOA 0010-12,Fire/Explosion," Revision 27, QCARP 0050-01, "SB-1-1 Injection with SSMP and Bring the Unit to Cold Shutdown," Revision 10, and other procedures which were referenced by procedure QCOA 0010-12. Procedure QCARP 0050-01 was the procedure for performing a plant alternative shutdown from outside the Unit 1 CR. The inspectors reviewed, on a sample bases, the ability of operators to perform procedure actionswithin applicable plant shutdown time requirements. The inspectors also focused on the feasability of the actions described in the procedure.The inspectors' reviews of the adequacy of communications and emergency lightingassociated with these procedures are documented in Sections 1R05.6 and 1R05.7 of this report.

b. Findings

b.1Fuse RepairIntroduction: The inspectors identified a NCV of 10 CFR Part 50, Appendix B,Criterion V, "Instruction, Procedures, and Drawings," having very low safety significance (Green) involving inadequate procedure steps. Specifically, the inspectors identified that Procedure QOP 6500-10, "Local Control of 4160 and 480 Volt Motor OperatedCircuit Breaker, Revision 8, included repair steps to replace fuses for hot shutdown in the event of a fire. This fuse replacement constituted a hot shutdown repair which did not meet 10 CFR Part 50, Appendix R requirements.Description: The breakers for Unit 1's Division 1 RHR pumps and Bus 13-1/23-1cross-tie are required to be opened and closed to safely shutdown the unit in the event of a fire in Fire Area TB-III. Each breaker had a cable routed in Fire Area TB-III, which 14had the potential to cause the breaker's control power fuses to be blown. This wouldhave prevented the electrical operation of the breakers but would not have preventedlocal manual operation as documented in QCNPS's Appendix R analysis. During the inspectors review of Procedure QCARP 0030-01 "TB-III Injection With SSMP andBringing the Unit to Cold Shutdown," Revision 8, the inspectors noted that inSteps D.11.e (e.g, closes Bus 23-1 and 13-1 cross-tie breaker) and D.11.f (e.g, closes one of the RHR pumps 1A or 1B) the operator(s) were required to close the circuitbreaker per procedure QOP 6500-10. Procedure QOP 6500-10 included a step to replace any fuses believed to be blown prior to operating the breaker from a local control box. The inspectors determined that since one train of RHR system wasrequired for torus cooling, the fuse replacement specified in this step constituted a hot shutdown repair.Title 10 CFR Part 50, Appendix R, Section III. G.1.a, stated "One train of systemsnecessary to achieve and maintain hot shutdown conditions from either the control room or emergency control station(s) is free of fire damage; . . ." and Section III.G.1.b, stated"Systems necessary to achieve and maintain cold shutdown from either the control or emergency station(s) can be repaired within 72-hours." Based on the above, the inspectors determined that the breaker's fuse replacement did not meet Appendix Rrequirements, because it constituted a hot shutdown repair, and repair is only allowed for systems necessary to achieve and maintain cold shutdown. As a result, the licenseeentered this finding into the station's corrective action program as IR 00485702, "Required SSDA Actions Not Contained in QCARP 0030-01," dated May 2, 2006. The licensee revised Procedure QOP 6500-10 and added steps to manually charge breaker's spring and close the breaker using a pushbutton if the fuses are not available due to fire damage.

Analysis:

The inspectors determined that the failure to include adequate steps inProcedure QOP 6500-10 that did not meet Appendix R requirements was a performance deficiency warranting a significance evaluation. The inspectors concluded that the finding was greater than minor in accordance with IMC 0612, "Power Reactor Inspection Reports," Appendix B, "Issue Screening," issued on September 30, 2005.

The finding involved the attribute of "Procedure Quality" and could have affected the mitigating systems cornerstone objective of ensuring the availability, reliability, andcapability of systems that respond to initiating events (fire) to prevent undesirableconsequences (i.e., core damage). Specifically, the failure to include adequate steps in the procedure to manually operate switchgear breakers and instead included a repair to achieve and maintain hot shutdown in the event of a fire could have delayed and complicated shutdown of the plant. The inspectors completed a significance determination of this finding using IMC 0609,"Significance Determination Process (SDP)," dated November 22, 2005, Appendix F, "Fire Protection Significance Determination Process," dated February 28, 2005. The inspectors assigned a degradation rating of low safety significance (Green) because the licensee's R analysis did not require the repair, and the operator(s) could have manually closed the breaker instead of replacing the fuses. Therefore, this finding screened out as having very low safety significance (Green).Enforcement: Title 10 CFR Part 50, Appendix B, Criterion V, stated, in part, thatactivities affecting quality shall be prescribed by documented instructions, procedures, 15or drawings of a type appropriate to the circumstances and shall be accomplished inaccordance with these instructions, procedures, or drawings. Title 10 CFR Part 50, Appendix R, Section III. G.1.a, stated "One train of systems necessary to achieve andmaintain hot shutdown conditions from either the control room or emergency control station(s) is free of fire damage; . . ." and Section III.G.1.b, stated "Systems necessaryto achieve and maintain cold shutdown from either the control or emergency station(s)can be repaired within 72-hours." Contrary to the above, Procedure QOP 6500-10, "Local Control of 4160 and 480 VoltMotor Operated Circuit Breaker, Revision 8, included steps that were not appropriate to the circumstances. Specifically, Procedure QOP 6500-10, included steps to replace the switchgear breaker's fuses prior to operation of the breaker from a local control box.

This fuse replacement constituted a hot shutdown repair which did not meet the requirement of 10 CFR Part 50, Appendix R and could have delayed SSD of the plant in the event of a fire. Once identified, the licensee entered the finding into their correctiveaction program as IR 00485702, "Required SSDA Actions Not Contained in QCARP 0030-01," dated May 2, 2006. Because this violation was of very low safety significance and it was entered into the licensee's corrective action program, this violation is being treated as a NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy (NCV 05000254/2006002-03(DRS);05000265/2006002-03(DRS))..6CommunicationsFor a fire in an alternative shutdown fire area, CR evacuation may be required and ashutdown is performed from outside the CR. Radio communications are relied upon to coordinate the shutdown of both units and for fire fighting and security operations.

Title 10 CFR Part 50, Appendix R, Section III.H., required that equipment provided forthe fire brigade include emergency communications equipment.

a. Inspection Scope

The inspectors reviewed, on a sample bases, the adequacy of the communicationsystem to support plant personnel in the performance of alternative SSD functions andfire brigade duties.

b. Findings

No findings of significance were identified..7Emergency LightingTitle 10 CFR Part 50, Appendix R, Section III.J., required that emergency lighting unitswith at least an 8-hour battery power supply be provided in all areas needed for operation of SSD equipment and in access and egress routes thereto.

a. Inspection Scope

The inspectors performed a plant walkdown of areas in which a sample of the actionswould be performed as described in procedure QCARP 0050-01, "SB-1-1 Injection with SSMP and Bring the Unit to Cold Shutdown," Revision 10, and other procedures which were referenced by procedure QCARP 0050-01. As part of the walkdowns, the inspectors focused on the existence of sufficient emergency lighting for access and egress to areas and for performing necessary equipment operations.

b. Findings

No findings of significance were identified..8Cold Shutdown RepairsTitle 10 CFR Part 50, Appendix R, Section III.L.5, required that equipment and systemscomprising the means to achieve and maintain cold shutdown conditions should not be damaged by fire; or the fire damage to such equipment and systems should be limited so that the systems can be made operable and cold shutdown achieved within 72-hours. Materials for such repairs shall be readily available onsite and procedures shall be in effect to implement such repairs.

a. Inspection Scope

The inspectors reviewed the licensee's procedures to determine if any repairs wererequired to achieve cold shutdown. The inspectors determined that the licensee did require repair of some equipment to reach cold shutdown based on the SSD methods used. The inspectors reviewed the procedures for adequacy. The inspectors also reviewed completed surveillances of the tools and equipment needed to reach cold shutdown.

b. Findings

No findings of significance were identified..9Fire Barriers and Fire Zone/Room Penetration SealsTitle 10 CFR Part 50, Appendix R, Section III.M, required that penetration seal designsbe qualified by tests that are comparable to tests used to rate fire barriers.

a. Inspection Scope

The inspectors reviewed the test reports for three-hour rated barriers installed in theplant and performed visual inspections of selected barriers to ensure that the barrier installations were consistent with the tested configuration. In addition, the inspectorsreviewed the fire loading for selected areas to ensure that existing barriers would not be challenged by a potential fire.

b. Findings

No findings of significance were identified..10Fire Protection Systems, Features, and Equipment

a. Inspection Scope

The inspectors reviewed the material condition, operations lineup, operationaleffectiveness, and design of fire detection systems, fire suppression systems, manualfire fighting equipment, fire brigade capability, and passive FP features. The inspectorsreviewed deviations, detector placement drawings, fire hose station drawings, carbon dioxide system pre-operational test reports, and fire hazard analysis reports to ensurethat selected fire detection systems, sprinkler systems, portable fire extinguishers, andhose stations were installed in accordance with their design, and that their design wasadequate given the current equipment layout and plant configuration.

b. Findings

b.1 Fire Pre-PlansIntroduction: The inspectors identified a NCV of QCNPS's Operating Licenses DPR-29and DPR-30, Section h.3.F, having very low safety significance (Green) involving the lack of pertinent information in the QCNPS's fire pre-plans for various plant fire areas.

Specifically, the licensee failed to include important information in the fire pre-plans, such as, hydrogen and electrical hazards, to assist the fire brigade to fight a fire within those plant fire areas.Description: The inspectors reviewed the licensee's corrective action documentsIR 00221528, "Fire Brigade Turnout Gear /SCBA Location," dated May 12, 2004, andIR 00478821, "Fire Pre-plans [Fire Area] RB-19 and [Fire Area] TB-71 Have Incorrect Information," dated April 14, 2006. Both issue reports were initiated as a result of the NRC resident inspector identified problems associated with the QCNPS's fire pre-plans. One of the licensee's corrective actions associated with IR 00221528 was the implementation of a plan to improve the fire pre-plans over a four year period. Each cycle would be six-months with the first cycle beginning July 2004 thru December 2004. The licensee maintained a log of the fire pre-plans reviewed during each cycle. Thelicensee's review of IR 00478821 noted that Fire Areas RB-7 and RB-19 needed hydrogen and oxygen hazards added to the fire pre-plans.The inspectors observed that Fire Area RB-7 was previously reviewed on July 8, 2004,and Fire Area RB-19 was previously reviewed on December 20, 2005, as part of the fire pre-plan improvement effort. The inspectors' review identified that the licensee's corrective actions to improve the QCNPS's fire pre-plans were not adequate. Major fire hazards, such as, hydrogen and oxygen hazards were missed during the licensee's review. In addition, the inspectors identified additional concerns regarding fire pre-plans as follows: 1) pre-plans did not identify all potential hazards (e.g., the location of electrical panels that could be a risk to the fire brigade); 2) pre-plans lacked adequate 19information on damper and ventilation controls (e.g., which damper and/or ventilationcontrols needed to be isolated or turned off and which must be left on to cool SSD equipment); 3) some pre-plan drawings contained errors (e.g., the quantity of fire fighting equipment available); 4) pre-plans failed to identify the electrical panels that were not sealed (e.g., to prevent water, if used during fire fighting, from entering unsealed electrical panels to eliminate potential damage to both trains of equipment; 5) pre-plans did not identify which hose reels were primary or secondary hose reels to ensure that the correct hose reel was used in a fire area (e.g., correct nozzle, length of hose, etc.); 6) pre-plans listed transient combustibles as a hazard, when transient combustibles may no longer be in the fire area and should have been removed from the fire pre-plan; 7) pre-plans listed cable insulation as a hazard when cable insulation is normally located in most fire areas; and 8) pre-plans allowed a person with a radio to be positioned at a sprinkler control valve, where in many cases the control valve located in the fire area .Fire pre-plan requirements were identified in the licensee's, "Fire Protection ReportVolume 1," Revision 17, dated October 2005, in Section 2.0, "Fire Protection Program",Paragraph 2.5.4, "Fire Fighting Strategies," which stated "Pre-fire plans are provided forall safety-related areas of the plant. The fire pre-plans provided necessary information, including a diagram showing where fire equipment is located to aid the fire brigade in executing manual fire fighting operations." In addition, in procedure CC-AA-211, "Fire Protection Program," Paragraph 4.9, "Fire Pre-Plans," the licensee stated, "The plans are designed to provide as much useful information as possible in a short amount of time, . . .." and ". . . they provide useful information for quickly determining the emergency response strategies based on hazards and equipment in the area."Analysis: The inspectors determined that failure to maintain complete and accurate firepre-plans was a performance deficiency warranting a significance evaluation. The inspectors concluded that the finding was greater than minor in accordance with IMC 0612, "Power Reactor Inspection Reports, Appendix B, "Issue Screening," issued on September 30, 2005. The finding involved the attribute of protection against externalfactors (i.e., fire), where failure to provide adequate warnings and guidance related to hydrogen and electrical hazards in the fire pre-plans could have adversely impacted the fire brigade's ability to fight a fire. This would increase the likelihood of a fire whichwould challenge SSD and could have affected the mitigating systems cornerstoneobjective of ensuring the availability, reliability, and capability of systems that res pond toinitiating events to prevent undesirable consequences (i.e., core damage). The inspectors determined that this issue also affected the cross-cutting area of Problem Identification and Resolution because the licensee failed to ensure that issues potentially impacting nuclear safety were identified and fully evaluated. The licensee failed to identify and revise the presence of hydrogen and oxygen hazards in Fire Areas RB-7 and RB-19 during their review as part of the fire pre-plan improvement effort conducted as a result of previously identified corrective action (IR 00221528).The inspectors completed a significance determination of this finding using IMC 0609,"Significance Determination Process," Appendix F, "FireProtection Significance Determination Process," dated February 28, 2005. The finding affected the Fire Prevention and Administrative Controls Category in the area of 20compliance documentation. The inspectors assigned a degradation rating of low safetysignificance because extensive training was provided to fire brigade members to deal with unexpected contingencies. In addition, other defense-in-depth FP elements remained unaffected and fire in this area would not result in a loss of dedicated SSD systems. The inspectors review of the "Initial Qualitative Screening" concluded that thisfinding was considered to be of very low safety significance (Green).Enforcement: The QCNPS's Operating Licenses DPR-29 and DPR-30, Section h.3.F,stated that the licensee shall implement and maintain in effect all provisions of the approved QCNPS's FPP as described in the UFSAR for the facility and as approved inthe SER dated July 27, 1979, and subsequent SER supplements. Section h.3.F, alsostated that the licensee may make changes to the approved QCNPS's FPP without priorapproval of the Commission only if those changes would not adversely affect the abilityto achieve and maintain SSD in the event of a fire. The licensee's procedure CC-AA-211, "Fire Protection Program," Paragraph 4.9, "Fire Pre-Plans" stated "The plans are designed to provide as much useful information as possible in a short amount of time, . . . ." and ". . . they provide useful information for quickly determining the emergency response strategies based on hazards and equipment in the area."Contrary to the above, on May 11, 2006, the licensee's fire pre-plans failed to provide useful information for quickly determining the emergency response strategies based on hazards and equipment in the area for effective fire fighting. Specifically, the licensee failed to maintain acceptable fire pre-plans by not providing accurate and complete and guidance related to hydrogen and electrical hazards in the fire pre-plans which could have adversely impacted fire brigade's ability to fight a fire. The inspectors concl udedthis was a violation of the QCNPS's License Condition, Section h.3.F. Once identified,the licensee entered the finding into their corrective action program as IR 00489175, "Quality of Fire Preplans (2006 FP Triennial)," dated May 11, 2006. Because this violation was of very low safety significance and it was entered into the licensee's corrective action program, this violation is being treated as a NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy (NCV 05000254/2006002-04(DRS);05000265/2006002-04(DRS)).

b.2 Standpipes with Hose ConnectionsIntroduction: The inspectors identified a NCV of Operating Licenses DPR-29 andDPR-30, Section h.3.F, having very low safety significance (Green) involving adequacy of water pressure and flow rate at standpipes with hose connections. Specifically, the licensee failed to provide calculations to ensure that an adequate water pressure and flow rate were available to meet the QCNPS's FPP requirements.Description: The inspectors were concerned that standpipes with hose connections hadthe potential for an inadequate water pressure and flow rate to effectively fight a fire.

The licensee stated that calculations had been made to ensure that an adequate waterpressure and flow rate were available, however, the licensee could not locate the supporting calculations.

21In NFPA 14, "Standpipe and Hose Systems," Revision 1974, the requirements forstandpipe systems in Class II service required that each standpipe shall be sized for aminimum flow of 100 gallons per minute and that standpipes in excess of 50 feet in height shall be at least 21/2 inches in size.The inspectors' review of the licensee's NFPA Code Deviation 14-06, indicated that afew standpipes serving multiple hose connections were less than four inches in diameter and several connections to single hose stations were less than 21/2 -inch diameter. The licensee's justification stated that calculations had been completed to verify the adequacy of the water supply from these small pipes. In addition, the inspectors noted that in the QCNPS's Fire Protection Report comparison against NRC Branch TechnicalPosition 9.5.1, Appendix A to 9.5-1 "Guidelines for Fire Protection," Paragraph E.3.(d),the licensee stated that several standpipes serving single hose connections were less than 21/2 inch in diameter and that calculations had been completed to verify the adequacy of the water supply from the smaller pipes.During this inspection, the licensee completed Calculation QDC-4100-M1534, "FireProtection Hose Reel Supply Piping Pressure Drop;" dated May 11, 2006, for one of the more limiting two inch FP supply pipelines to demonstrate that the NFPA Code requirements were met. However, the inspectors concluded that this calculation failed to account for the more limiting 11/2 inch piping to the standpipes with hose connections used in the QCNPS's turbine building. The inspectors' review revealed that the calculation did not account for the water supply pressure drop that would occur at eitherthe fire area sprinklers or the standpipes with hose connections when a concurrent actuation was initiated. The inspectors' review of the two inch piping calculation also revealed that there was little or no margin in water flow rate in the 11/2 inch piping. As a result, the licensee initiated IR 00489160, "Justification of Fire Hose Pressure and Flow Meeting NFPA," dated May 11, 2006, to include in their corrective actions a plan to perform more extensive calculations to verify water pressure and flow rate at all effected standpipes with hose connections.

Analysis:

The inspectors determined that failure to provide supporting calculations todemonstrate adequate water pressure and flow rate at standpipes with hose connections was a performance deficiency warranting a significance evaluation. The inspectors concluded that the finding was greater than minor in accordance with IMC 0612, "Power Reactor Inspection Reports, Appendix B, "Issue Screening," issued on September 30, 2005. The finding involved the attribute of protection against externalfactors (i.e., fire), where the lack of water pressure and flow rate at standpipes with hose connections could hamper the fire brigades ability to fight a fire, thereby, increasing thelikelihood of a fire which would challenge SSD and could have affected the mitigating systems cornerstone objective of ensuring the availability, reliability, and capability ofsystems that respond to initiating events to prevent undesirable c onsequences(i.e., core damage).The inspectors completed a significance determination of this finding using IMC 0609,"Significance Determination Process," dated November 22, 2005, Appendix F, "Fire Protection Significance Determination Process," dated February 28, 2005. The finding affected the Fire Prevention and Administrative Controls Category in the area of compliance documentation. The inspectors assigned a degradation rating of low safety significance because other defense-in-depth FP elements remained unaffected in all fire 22areas. The inspectors review of the "Initial Qualitative Screening" concluded that thisfinding was considered to be of very low safety significance (Green).Enforcement: The QCNPS's Operating Licenses DPR-29 and DPR-30, Section h.3.F,stated that the licensee shall implement and maintain in effect all provisions of the approved QCNPS's FPP as described in the UFSAR for the facility and as approved inthe SER dated July 27, 1979, and subsequent SER supplements. Section h.3.F, alsostated that the licensee may make changes to the approved QCNPS's FPP without priorapproval of the Commission only if those changes would not adversely affect the abilityto achieve and maintain SSD in the event of a fire. In addition, the licensee stated in Appendix A to 9.5-1 "Guidelines for Fire Protection," Paragraph E.3.(d) that severalstandpipes serving single hose connections were less than 21/2 inch in diameter and that calculations had been completed to verify the adequacy of the water supply from these smaller pipelines.Contrary to the above, on May 11, 2006, the licensee failed to provide calculations toensure adequate water pressure and flow rate were available at standpipes with hose connections for effective fire fighting. The inspectors concluded this was a violation of the QCNPS's License Condition, Section h.3.F. Once identified, the licensee enteredthe finding into their corrective action program as IR 00489160, "Justification of Fire Hose Pressure and Flow Meeting NFPA," dated May 11, 2006, and planned to perform calculations to verify water flow at all effected standpipes with hose connections.

Because this violation was of very low safety significance and it was entered into the licensee's corrective action program, this violation is being treated as a NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy (NCV 05000254/2006002-05(DRS);05000265/2006002-05(DRS)).

b.3 Class A Fire ExtinguishersIntroduction: The inspectors identified a NCV of QCNPS's Operating Licenses DPR-29and DPR-30, Section h.3.F, having very low safety significance (Green) involving Class A fire extinguishers. Specifically, the QCNPS's FPP did not have an adequate number of Class A fire extinguishers available where significant fire hazards existed to meet the NFPA 10 Code requirements to suppress and/or extinguish Class A fire hazards.Description: The inspectors reviewed Design Analysis WDC-4100-0691, "CombustibleLoading Calculation for the Power Block, SBO Building, and Cribhouse," dated February 18, 2005. This document showed large quantities of Class A combustibles located in many areas of the plant. For example, Fire Zones 1.1.1.5, 1.1.1.6, and8.2.7.A contained greater than 1000 pounds of Class A combustible materia..During the inspectors plant walkdown, the inspectors observed that there were aninadequate number of Class A fire extinguishers located throughout QCNPS where 23significant fire hazards existed to meet the NFPA 10 Code requirements. For example,fire zones 1.1.1.5, 1.1.1.6, and 8.2.7.A did not have Class A fire extinguishers present. The NFPA 10 Code requirements were endorsed by the QCNPS's FPP. Specifically, there were substantial amounts of Class A combustibles located in many areas of the plant that would require a Class A fire extinguisher to suppress and/or extinguish this type of fire hazard.In Amendment Number 52 to the Facility Operating License (SER dated July 27, 1979),Paragraph 4.3.3, "Portable Fire Extinguishers," the SER stated in part, that portable drychemical and carbon dioxide extinguishers have been distributed throughout the plant.

The fire extinguishers meet the NFPA 10 Code requirements. The fire extinguisher selections were made in accordance with the type of fire hazards to be protected against at the QCNPS. In addition, the licensee's responses to the "Guidelines ofAppendix A to APCSB 9.5-1," Section E.6, "Portable Extinguishers," stated in part, thatQCNPS complied with the NFPA 10 Code requirements for fire extinguishers. The NRC originally approved the licensee's statement of compliance with the NFPA Code during the NRC's review of the licensee' response to APCSB 9.5.1. The licensee subsequentlyrevised their statement of compliance with the APCSB 9.5-1 section for Class A fire extinguishers and instead took credit for standpipes with hoses in lieu of the Class A fire extinguishers. However, when the inspectors requested the licensee's evaluation that made this change to the QCNPS's FPP, the licensee could not locate the associateddocumentation.The inspectors' noted during a review of NFPA 10, "Portable Fire Extinguishers,"Revision 1975, that up to one-half of the complement of fire extinguishers may be replaced by uniformly spaced small hose stations for use by the building occupants. In addition, Section 1-1, "Standard for Portable Fire Extinguishers," stated in part, that portable fire extinguishers were intended as a first line of defense to cope with fires of limited size. The fire extinguishers were needed even though the property is equipped with automatic sprinklers, standpipes and hose, and other fixed fire protection equipment. The NFPA Code further stated that Class A fires were fires of ordinary combustible materials, such as wood, cloth, paper, rubber, and many plastics. In Section 2-2.1, the NFPA Code required that fire extinguishers shall be selected for the specific class or classes of fire hazards. Fire extinguishers for protecting Class A fire hazards shall be selected from among water types, foam, loaded stream, and multipurpose dry chemical.The inspectors' review of the QCNPS's NFPA Code Deviation 10-01 revealed that fireextinguishers for Class A fire hazards were not distributed in accordance with the NFPA Code. The licensee's justification, for the NFPA Code deviation, stated that at QCNPSthe quantity of Class A combustibles was limited primarily to cable insulation and/or transient combustibles, that proper distribution of standpipes with hose connections were provided, and since trained on-site fire brigade personnel were present that the limited distribution of Class A fire extinguishers was considered acceptable. As a result of the inspectors' review of Design Analysis WDC-4100-0691, the inspectors concluded that the licensee's NFPA Code Deviation 10-01, as stated above, contained aninadequate justification for the number of Class A fire extinguishers in the plant.

24Analysis: The inspectors determined that failure to have an adequate number ofClass A fire extinguishers available where significant fire hazards existed to meet the NFPA 10 Code requirements to suppress and/or extinguish Class A fire hazards was a performance deficiency warranting a significance evaluation. The inspectors concluded that the finding was greater than minor in accordance with IMC 0612, "Power Reactor Inspection Reports, Appendix B, "Issue Screening," issued on September 30, 2005.

The finding involved the attribute of protection against external factors (i.e., Fire), where failure to have an adequate number of Class A fire extinguishers available could potentially escalate a small fire into a larger fire since only standpipes with hose connections were available and their use required a trained fire brigade to extinguish the fire. As a result, non-fire brigade personnel would be prevented from moving quickly to suppress and/or extinguish a small fire and the potential for an escalated fire could have affected the mitigating systems cornerstone objective of ensuring the availability,reliability, and capability of systems that respond to initiating events to preventundesirable consequences (i.e., core damage).The inspectors completed a significance determination of this finding using IMC 0609,"Significance Determination Process," dated November 22, 2005, Appendix F, "Fire Protection Significance Determination Process," dated February 28, 2005. The finding affected the Fire Prevention and Administrative Controls Category in the area of compliance documentation. The inspectors assigned a degradation rating of low safety significance because most fire areas and fire zones have fire detectors that would alarm in the control room. In addition, other defense-in-depth FP elements remained unaffected and fire in this area would not result in a loss of dedicated SSD systems. The inspectors review of the "Initial Qualitative Screening" concluded that this finding was considered to be of very low safety significance (Green).Enforcement: The QCNPS's Operating Licenses DPR-29 and DPR-30, Section h.3.F,stated that the licensee shall implement and maintain in effect all provisions of the approved QCNPS's FPP as described in the UFSAR for the facility and as approved inthe SER dated July 27, 1979, and subsequent SER supplements. Section h.3.F, alsostated that the licensee may make changes to the approved QCNPS's FPP without priorapproval of the Commission only if those changes would not adversely affect the abilityto achieve and maintain SSD in the event of a fire. Amendment Number 52 to the Facility Operating License (SER dated July 27, 1979), required the QCNPS to maintainClass A fire extinguishers in accordance with NFPA 10 Code requirements and that Class A fire extinguishers would be available for the type of fire hazard present.Contrary to the above, from May 24, 1985, to May 12, 2006, the licensee failed tomaintain Class A fire extinguishers in accordance with NFPA 10 Code requirements and that Class A fire extinguishers were not available for the type of fire hazard present.

Specifically, no Class A fire extinguishers were located within Fire Zone 1.1.1.5, 1.1.1.6and 8.2.7.A even though the fire zones contained more than 1000 ponds of Class Acombustible materials. Additionally, the licensee's code evaluation 10-01 was not consistent with the results in Design Analysis WDC-4100-0091. The inspectors concluded this was a violation of the QCNPS's License Condition, Section h.3.F. Once identified, the licensee entered the finding into their corrective action program asIR 00489426, "Class A Fire Extinguisher Placement Improvements," dated May 12, 2006. Because this violation was of very low safety significance and it was entered into 25the licensee's corrective action program, this violation is being treated as a NCV,consistent with Section VI.A.1 of the NRC Enforcement Policy (NCV 05000254/2006002-06(DRS);05000265/2006002-06(DRS)).

26.11Compensatory Measures

a. Inspection Scope

The inspectors conducted a minimal review to verify that adequate compensatorymeasures were put in place by the licensee for out-of-service, degraded or inoperable FP and post-fire SSD equipment, systems, or features. The inspectors also conducteda minimal review on the adequacy of short term compensatory measures to compensate for a degraded function or feature until appropriate corrective actions were taken.

b. Findings

No findings of significance were identified.4.OTHER ACTIVITIES 4OA2Identification and Resolution of Problems

a. Inspection Scope

The inspectors reviewed the corrective action program procedures and samples ofcorrective action documents to verify that the licensee was identifying issues related to the FPP at an appropriate threshold and entering them in the corrective action program.

The inspectors reviewed these issues to verify an appropriate threshold for identifying issues and to evaluate the effectiveness of corrective actions related to the FPP. In addition, corrective action documents written on issues identified during the inspection were reviewed to verify adequate problem identification and incorporation of the problem into the corrective action system. The specific corrective action documents that weresampled and reviewed by the team are listed in the attachment to this report.

b. Findings

No findings of significance were identified.4OA5Other Activities(Closed) Unresolved Item 05000254/2003012-01(DRS);05000265/2003012-01(DRS):Cable Ampacity Calculation MethodologyA Unresolved item (URI) was opened during the 2003 triennial FP inspection regardingCalculation QDC-0000-E-0853, "SLICE Cable Ampacity Multiplying Factors for Quad Cities," Revision 0, dated December 2, 1999. Specifically, the inspectors were concerned that the calculation's methodology used to account for cable derating and/orcable tray loading was correctly applied to potential overpowered cables. The URI was opened pending further NRC review of the licensee's calculation.During this inspection, the inspectors reviewed the licensee's activities associated withcable ampacity derating and cable tray ampacity loading. The results of the inspectors' review indicated that the QCNPS's Calculation QDC-0000-E-0853 was not utilized at the 27QCNPS. As a result, no further inspector concerns were identified with this calculationat the present time. Since the calculation was not utilized at QCNPS, the inspectors considered this URI closed.4OA6Meetings.1Exit MeetingOn May 12, 2006, at the end of the on-site inspection activities, the inspectorspresented the inspection results to Mr. T. Tulon and other members of licensee management. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.On June 29, 2006, at the conclusion of the inspection, a re-exit meeting conference callwas with Mr. T. Tulon and other members of licensee management to present the inspection findings..2Interim Exit MeetingsNo interim exits were conducted.4OA7Licensee-Identified ViolationsThe following violations of very low safety significance (Green) were identified by thelicensee and are violations of NRC requirements which meet the criteria of Section VI ofthe NRC Enforcement Policy, NUREG-1600, for being dispositioned as NCVs.Cornerstone: Mitigating System.1Appendix R SSD Battery LoadsCriterion III "Design Control," of 10 CFR Part 50, Appendix B, requires, in part, thatmeasures shall be established to assure that applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures, and instructions. Contrary to the above, the licensee did not have a design basis calculation to verify that the 125Vdc battery/system can support the SSD loads during anAppendix R fire for the period of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Specifically, the licensee did not consider the additional loads lineup to battery 2 as a result of a fire in Fire Area 13-1. During normal plant operating conditions, the 125Vdc battery 1 supplied Bus 1A (Unit 1 Division I) and Bus 2B (Unit 2 Division II), battery 2 supplied Bus 2A (Unit 2 Division I) and Bus 1B (Unit 1 Division II). In the event of a fire in Fire Area 13-1, both battery chargers for battery 1 were considered unavailable. Procedure QCARP 0040-01 "13-1 Injection with SSMP and Bringing the Unit to Cold Shutdown" included steps connected the Unit 2 Division II, 125Vdc Bus 2B, to battery 2. These steps in the procedure would have lined-up all three 125Vdc divisions to battery 2. A calculation was not performed to ensure that the 125Vdc battery/charger could have provided power to three divisions simultaneously. The inspectors determined that the finding was more than minor because it was associate with the Mitigating System Cornerstone attribute of "Design 28Control" and affected the cornerstone objective of ensuring the capability of systemsneeded to respond to initiating events to prevent undesirable consequences.

Specifically, the failure of the fuse or the battery/charger to supply the necessary loads for 72-hours could potentially have complicated shutdown during a fire event. The licensee discovered this finding during their Focus Area Self Assessment (FASA) and tracked it through Action Tracking AT 426687-15. The licensee also entered this finding into the station's corrective action program as IR 00492546. The inspectors determined that the finding was of very low safety significance because the licensee completed technical evaluation EC 360895 which ensured that the battery, main fuse and charger number 2 were adequate to supply the loads lineup included in procedure QCARP 0040-01..2Post-Fire Operator Manual ActionsOn March 6, 2006, the NRC published a Federal Register Notice (FRN, Vol. 71, No. 43,Page 11169, 10 CFR Part 50, RIN 3150 AH54) that announced the withdrawal of a proposed rule to 10 CFR Part 50, Appendix R, Paragraph III.G.2. The proposed rulewould have revised Paragraph III.G.2 of Appendix R to allow licensees to implementacceptable operator manual actions combined with fire detectors and automatic fire suppression capability as an acceptable method for ensuring the capability of a licenseeto bring a reactor to, and maintain it in, a hot shutdown condition. The NRC withdrewthe proposed rule stating that 10 CFR Part 50, Appendix R, Paragraph III.G.2, cannotbe reasonably interpreted to permit reliance upon operator manual actions in lieu of the specific methods provided in the subparagraphs of Paragraph III.G.2, to ensure that oneof the redundant SSD trains in the same fire area is free of fire damage. Therefore, any pre-1979 licensee (i.e., QCNPS) that is using operator manual actions instead of the specific methods provided in the subparagraphs of Paragraph III.G.2, without an NRC-approved exemption, is not in compliance with the regulations.Contrary to the requirements of 10 CFR Part 50, Appendix R, Paragraph III.G.2, theQCNPS's FPP permitted reliance upon operator manual actions in lieu of the specific methods provided in the subparagraphs of Paragraph III.G.2, to ensure that one of theredundant SSD trains in the same fire area is free of fire damage. The licensee recognized that many of the QCNPS's FPP operator manual actions were without

NRC-approved exemptions. As a result, the licensee generated Issue Report00464665, "NRC Terminates Fire Protection Manual Action Rulemaking," dateMarch 10, 2006, to acknowledge withdrawal of the proposed rule and QCNPS's nonconformance to the regulatory requirements. Since the licensee did not dispute thata violation of regulatory requirements had occurred, enforcement discretion has beenexercised in accordance with EGM 98-002, Revision 2, dated February 2, 2000. The licensee has initiated corrective actions to resolve this finding within a reasonable time frame in accordance with the published EGM and FRN. Therefore, this finding is of very low safety significance.ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

W. Beck, Regulatory Assurance Manager

D. Boyles, Operations

D. Bucknell, FP Engineer

J. Burkhead, Quad Cities Nuclear Oversight

R. Buttke, Design Engineering

T. Fuhs, Regulatory Assurance

J. Garrity, Outage Control

L. Geerts, Fire Marshal

R. Gideon, Plant Manager

D. Gullott, Corporate Licensing

T. Hanley, Dresden Director of Site Engineering

K. Moser, Quad Cities Director of Site Engineering

C. Pragman, Corporate Fire Protection

J. Rathman, Design Engineering

S. Reynolds, Fire Protection System Engineer

T. Scott, Operations

P. Simpson, Corporate Licensing

M. Taylor, Corporate Fire Protection

T. Tulon, Site Vice President

M. Wagner, Regulatory Assurance

D. Wolf, Design Engineering

NRC

L. Kozak, RIII Senior Reactor Analyst

M. Kurth, Resident Inspector

J. Lara, RIII Engineering Branch 3 Chief

K. Stoedter, Senior Resident Inspector

AttachmentA-2

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

05000254/2006002-01(DRS);05000265/2006002-01(DRS)NCVSSMP Credited as a Redundant System for anAppendix R III.G.2 Fire Area (Section 1R05.1b.1)05000254/2006002-02(DRS);05000265/2006002-02(DRS)NCVFailure to Ensure One Redundant Train of RHRSWFree of Fire Damage (Section 1R05.1b.2)05000254/2006002-03(DRS);05000265/2006002-03(DRS)NCVProcedure Included Unapproved Fuse Repair forAppendix R (Section 1R05.5b.1)05000254/2006002-04(DRS);05000265/2006002-04(DRS)NCVFailure to Maintain Acceptable Pre-Fire Plans(1R05.10b.1)05000254/2006002-05(DRS);05000265/2006002-05(DRS)NCVFailure to Have a Calculation for Hose Stations That DidNot Meet Code Requirements to Ensure Adequate

Water Pressure and Flow Rate (1R05.10b.2)05000254/2006002-06(DRS);05000265/2006002-06(DRS)NCVFailure to Meet NFPA Code Requirements for Class AFire Extinguishers (1R05.10b.3)

Closed

05000254/2006002-01(DRS);05000265/2006002-01(DRS)NCVSSMP Credited as a Redundant System for anAppendix R III.G.2 Fire Area (Section 1R05.1b.1)05000254/2006002-02(DRS);05000265/2006002-02(DRS)NCVFailure to Ensure One Redundant Train of RHRSWFree of Fire Damage (Section 1R05.1b.2)05000254/2006002-03(DRS);05000265/2006002-03(DRS)NCVProcedure Included Unapproved Fuse Repair forAppendix R (Section 1R05.5b.1)05000254/2006002-04(DRS);05000265/2006002-04(DRS)NCVFailure to Maintain Acceptable Pre-Fire Plans(1R05.10b.1)05000254/2006002-05(DRS);05000265/2006002-05(DRS)NCVFailure to Have a Calculation for Hose Stations That DidNot Meet Code Requirements to Ensure Adequate

Water Pressure and Flow Rate (1R05.10b.2)05000254/2006002-06(DRS);05000265/2006002-06(DRS)NCVFailure to Meet the NFPA Code Requirements forClass A Fire Extinguishers (1R05.10b.3)05000254/2003012-01(DRS);05000265/2003012-01(DRS)URICable Ampacity Calculation Methodology(Section 4OA5)

Discussed

None.

AttachmentA-3

LIST OF DOCUMENTS REVIEWED

The following is a list of documents reviewed during the inspection.

Inclusion on this list doesnot imply that the NRC inspectors reviewed the documents in their entirety, but rather, that selected sections of portions of the documents were evaluated as part of the overall inspection effort.

Inclusion of a document on this list does not imply NRC acceptance of the document orany part of it, unless this is stated in the body of the inspection report.CALCULATIONSNumberDescription or TitleDate or Revision9198-13-19-1Calc for SLICE Cable Ampacity Multiplying Factors for theDresden and Quad Cities Stations, Rev 0August 24, 1994DQAMPACVer 1.1Revised Cable Tray Power Cable Ampacities (S-141A)April 24, 2006QDC-0000-E-0853SLICE Cable Ampacity Multiplying Factors for QCNPS, Rev 0December 2, 1999QDC-3300-M-0542Determine Usable Volume in CCSTs for SSMP or RCICfollowing an App R Fire Event

1WDC-4100-0691Combustible Load Calc for Pwr Block, SBO Bldg and Crib HseFebruary 18, 2005CORRECTIVE ACTION PROGRAM DOCUMENTS ISSUED DURING INSPECTIONNumberDescription or TitleDate or Revision00483345FP Report Volume 1 Part 2.1-2 Needs CorrectionApril 26, 200600483355Inconsistent Information in the SSDRApril 26, 2006

00483752Discrepancies Have Been Identified in the FHA Table 2.1-2April 27, 2006

00485387NFPA Code Deviations ImprovementMay 1, 2006

00485413Measure Currents Flowing in CablesMay 1, 2006

00485702Required SSDA Actions Not Contained in QCARP 0030-01May 2, 2006

00487902SLICE Program Cable Ampacity IssuesMay 8, 2006

00488593Update FP NFPA DeviationsMay 10, 2006

00489145Missing Reference Letter for FP NFPA Code DeviationsMay 11, 2006

00489160Justification of Fire Hose Pressure and Flow Meeting NFPAMay 11, 2006

00489175Quality of Fire Preplans (2006 FP Triennial)May 11, 2006

00489285Relay Setting Changed Without Revising CalculationMay 11, 2006

00489426Class A Fire Extinguisher Placement ImprovementsMay 12, 2006

00492546No Calc for 125Vdc QCARP LineupMay 22, 2006

00502702NRC Inspection Finding Concerning App R Redundant TrainsJune 22, 2006CORRECTIVE ACTION PROGRAM DOCUMENTS ISSUED PRIOR TO INSPECTIONNumberDescription or TitleDate or Revision00040209Q2000-04344 Certain FP Commitments in the 1979December 12, 2000 00113343Incomplete App R Revisions to Tray Routing NumbersJune 26, 2002

00180384Cable Ampacity Input Discrepancies in SLICE DatabaseOctober 10, 2003

00182702Deficiency Identified in Calculation

QDC-0000-E-0853October 24, 2003

CORRECTIVE ACTION PROGRAM DOCUMENTS ISSUED PRIOR TO INSPECTIONNumberDescription or TitleDate or RevisionAttachmentA-400218683Existing Cables Not Populated in the SLICE DatabaseMay 4, 200400221528Fire Brigade Turnout Gear/SCBA LocationMay 12, 2004

230758Wrong Unit Designation on Fire Pre-Plan

TB-71June 23, 2004

293853Discrepancy On Fire Pre-plan

TB 112 InformationJanuary 25, 2005

00464665NRC Terminates FP Manual Action RulemakingMarch 10, 200600478821Fire Pre-plans

RB-19 and

TB-71 Have Incorrect InformationApril 14, 2006DRAWINGSNumberDescription or TitleDate or Revision4E-7573CS/D ATWS Recirc Pump Trip Sys Div I and II -Part 3 04E-6613AS/D MOVs 1/2-2901-6 and 7 SSD System F4E-1344S/D 4160V Buses 13-1 and 14-1 Main FeedBreakers

JM-3General Arrangement Main Floor PlanKM-4General Arrangement Mezzanine Floor PlanH

M-6General Arrangement Basement Floor PlanC

M-70Diagram of SSMP SystemW

QDC-0000-E-1038, Attach FApp R AC Distribution Diagram0QDC-0000-E-1038,Attach F, Pg 2 of 3App R 250Vdc Distribution Diagram, Rev 0November 14, 2000QDC-0000-E-1038,Attach F, Pg 3 of FinalApp R 125Vdc Distribution Diagram, Rev 0November 13, 2000ENGINEERING ACTION PLANSNumberDescription or TitleDate or Revision00-00-24, Rev 0SLICE Program and Backlog ReductionFebruary 19, 200100-00-24, Rev 1SLICE Program and Backlog ReductionMarch 28, 2001

00-00-24, Rev 2SLICE Program and Backlog ReductionOctober 15, 2004ENGINEERING CHANGES (ECs)NumberDescription or TitleDate or Revision354100 001Abandonment of CO

Hose ReelsDecember 9, 20050000360804Address Triennial Fire Inspection Tray Ampacity IssuesRelated to Tray Nodes 261M1, 320B, 323M, 325B, and 329BMay 9, 20060000360805Evaluate SLICE Cable Ampacity Issues in Response toTriennial FP Inspection RequestMay 8, 2006EVALUATIONSNumberDescription or TitleDate or Revision----------------Portable Fire Extinguishers (NFPA 10 and 10A)May 24, 1985

EVALUATIONSNumberDescription or TitleDate or RevisionAttachmentA-5----------------Std for Installation of Standpipe and Hose Systems (NFPA 14)June 19, 1985----------------Fire Doors in Nuclear SR AreasApril 9, 1987----------------FP Survey of HVAC Systems in Computer/Nuclear SR Areas8IMPAIRMENT/REMOVAL PERMITSNumberDescription or TitleDate or Revision----------------List of Plant FP ImpairmentsApril 26, 2006PROCEDURESNumberDescription or TitleDate or RevisionCC-AA-211Fire Protection Program2CC-AA-302Control of the Cable Management Database2

QCOA 0010-12Fire/Explosion27

QCARP 0030-01TB-III Injection with SSMP and Bringing the Unit to Cold

SD 8QCARP 0040-0113-1 Injection with SSMP and Bringing the Unit to Cold

SD 7QCARP 0040-0224-1 Injection with SSMP and Bringing the Unit to Cold

SD 9QCARP 0050-01SB-1-1 Injection with SSMP and Bring the Unit to Cold

SD 10QCMMS 4100-61Fire Door Inspection11QCOP 2900-02SSMP System Start Up18

QOP 6500-10Local Control of 4160 and 480V MOV Circuit Breakers8 and 9REFERENCESNumberDescription or TitleDate or Revision----------------Pre-fire Strategies for Reactor Bldg and Turbine BldgApril 26, 2006FPR Vol 1 and 2QCNPS's Fire Protection ReportOctober 2005

GE Spec 22A2501GE Specification for Domestic Turnkey Projects0

GE-NE-T43-00002-00-01-R01Original SSD Paths for the BWR1GE-NE-T43-00002-00-03-R01BWROG Position on the Use of Safety Relief Valvesand Low Pressure Systems as Redundant SSD Paths

1NFPA 14Standpipe and Hose Systems1974NFPA 10Portable Fire Extinguishers1975

Q-ECDS-960134QCNPS Cable Ampacity ReportJuly 30, 1996

SandL

LTRD-3477EComEd SLICE Discrepancy Resolution ProjectDecember 23, 1999SandL

LTRQ-2148EComEd QCNPS Ampacity Evaluation InfoJuly 2, 1996NUREG/CR-6681(SAND2000-1825)Ampacity Derating and Cable Functionality forRaceway Fire BarriersAugust 2000SandL ProgramNo. 03.7.528-1.1DQAMPAC User's Manual - Revised SLICE AmpacitySoftwareAugust 31, 1995

AttachmentA-6

AttachmentA-7

LIST OF ACRONYMS

USEDAC or acAlternating Current

ADAMSAgency-Wide Document Access and Management System

AppAppendix

ATTNAttention

BWROGBoiling Water Reactor Owners Group

CFRCode of Federal Regulations

CRC ontrol Room

DC or dcDirect Current

DPRDemonstration Power Reactor

DRPDivision of Reactor Projects

DRSDivision of Reactor Safety

FPFire Protection

FPPFire Protection Program

GLGeneric Letter

FRNFederal Register Notice

IMCInspection Manual Chapter

IPInspection Procedure

IPEEEIndividual Plant Examination of External Events

IRInspection Report

kkilo

LLCLimited Liability Com

panyMOVMotor Operated Valve

NFPANational Fire Protection Association

NRCNuclear Regulatory Commission

NRROffice of Nuclear Reactor Regulation

NUREGNRC Technical Report DesignationPARSPublicly Available Records

QCNPSQuad Cities Nuclear Power Station

RIIIR egion

III [[]]

RHRSWResidual Heat Removal Service WaterS/DSchematic Diagram

SandLSargent and Lundy

SDShutdown

SDPSignificance Determination Process

SERSafety Evaluation Report

SLICESargent and Lundy Interactive Cable Engineering

SRSafety Related

SSASafe Shutdown Analysis

SSCASafe Shutdown Capability AssessmentSSCsStructures, Systems and Components

SSDSafe Shutdown

SSMPSafe Shutdown Makeup Pump

SSSASafe Shutdown System Analysis

UFSARUpdated Final Safety Analysis Report

URIUnresolved Item

AttachmentA-8