IR 05000206/1991003

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Forwards Enforcement Conference Rept 50-206/91-03 on 920107. Meeting Held to Discuss Circumstances & Apparent Violations Re Inoperability of Halon Fire Suppression Sys for 4160-volt Switchgear Room in Conflict W/Tech Specs.Agenda Also Encl
ML13333A146
Person / Time
Site: San Onofre Southern California Edison icon.png
Issue date: 02/05/1992
From: Zimmerman R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To: Ray H
SOUTHERN CALIFORNIA EDISON CO.
Shared Package
ML13333A148 List:
References
EA-91-198, NUDOCS 9202240011
Download: ML13333A146 (4)


Text

1,5 C;UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION V

1450 MARIA LANE WALNUT CREEK, CALIFORNIA 94596-5368 FE 1992 Docket No. 50-206 License No. DPR-13 EA No.91-198 Southern California Edison Company Irvine Operations Center 23 Parker Street Irvine, California 92718 Attention: Mr..Harold B. Ray, Senior Vice President, Nuclear Gentlemen:

This refers to the enforcement conference held with Southern California Edison Company by NRC Region V and NRR at the Region V office on January 7, 199 Subjects discussed during the meeting are described in the enclosed Meeting Report. A copy of the conference agenda is also attache The purpose of this enforcement conference was to discuss the circumstances and apparent violations associated with (1) inoperability of the Halon fire suppression system for the 4160-volt (4 kv) switchgear room, in apparent conflict with the Unit 1 Technical Specifications (TS); (2) inaccurate or incomplete statements in a licensee event report (LER) asserting that a design basis fire in the 4 kv room would not have prevented Unit 1 from achieving and maintaining safe shutdown, in apparent conflict with 10 CFR 50.9; and (3) failure of the fire protection test program to demonstrate operability of the 4 kv room Halon system slave bottle actuators as required by the Topical Quality Assurance Manua Failure to meet regulatory requirements for protecting trains of equipment required for achieving and maintaining safe shutdown is considered by the NRC to be serious. We acknowledge your evaluation which shows an overall low probability of a fire which could result in your inability to achieve safe shutdown of the Unit. However, inoperability of the 4 kv room Halon system resulted in loss of a significant fire protection feature. In addition, one other important safe shutdown feature, the dedicated safe shutdown (DSD)

system, was concurrently unavailable during a number of periods while the Halon system was inoperable. The NRC considers that these conditions repre sented a substantial degradation in the defense-in-depth concept of fire protection during those periods of time. We also stress the importance of your providing complete and accurate information to the NRC so that proper evaluations of conditions at the facility can be mad Enforcement action related to the issues discussed above and in the enclosed report will be the subject of separate correspondenc PDR ADOCK 05000206 ci PDR

-2-1992 In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosed meeting report.will be placed in the NRC Public Document Roo Should you have any questions concerning this report, we will be pleased to discuss them with yo

Sincerely, R. P. Zimmerman, Director Division of Reactor Safety and Projects

Enclosures:

1. Copy of Meeting Agenda 2. Meeting Report No. 50-206/92-03

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Enclosure 1 ENFORCEMENT CONFERENCE SOUTHERN CALIFORNIA EDISON COMPANY NRC Region V Office January 7, 1992 AGENDA 1. Opening Remarks, Purpose of Conference --

B. H. Faulkenberry, Deputy Regional Administrator, and H. B. Ray, Senior Vice President, Nuclear 2. Discussion of Apparent Violations Related to Halon Fire Suppression System for the 4 kv Switchgear Room -- P. H. Johnson, Chief, Reactor Projects Section 3 3. Discussion of Licensing Basis for Fire Protection Technical Specifica tions --

Edison Staff 4. Discussion of Safety Significance of the Apparent Violations -

R. P. Zimmerman, Director, Division of Reactor Safety and Projects 5. Licensee Response to Apparent Violations and Special Inspection Report Edison Staff 6. Review of Enforcement Policy --

F. R. Huey, Enforcement Officer 7. Other Discussion as Appropriate Closing Remarks --

B. H. Faulkenberry, Deputy Regional Administrator, and H. B. Ray, Senior Vice President, Nuclear