ML20031A062
| ML20031A062 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 08/25/1981 |
| From: | Chaffee A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20031A061 | List: |
| References | |
| 50-206-81-25, NUDOCS 8109180342 | |
| Download: ML20031A062 (4) | |
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APPENDIX A NOTICE OF VIOLATION Southern California Edison Company Docket v. 50-206 As a result of the inspection conducted on July 13-17, 1931, and in accordance with the Interin Enforcement Policy, 45 FR 66754 (October 7,1980), the following violation was identified:
License No. DPR-13 section 3.H. " Fire Protection", last paragraph,
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states, "The licensee is required to implement the administrative controls identified in section 6 of the SE. The administrative controls shall be in effect within 90 days from the date of issuance of this amendment."
(Note:
This amendment was dated 7/19/79.
"SE" refers to the NRC's Fire Protection Safety Evaluation Report dated July 19,1979).
Section 6, "Administrathe Cont: 01s" of the SE states in part, "We have subsequently recomended that the licensee's administrative controls follow the NRC guidelines set forth in " Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls and Ouality Aer irance."
(hereafter referred to as the Guidance)..."During the site vist exit meeting on July ll,1978, the licensee accepted the staff pr itions nn administrative controls."
1.
Attachnent No. 5 " Fire Fighting Procedures" of the Guidance states:
The fire fighting procedures should identify:
"d.
The strategies established for fighting fires in all safety-related areas and areas presenting a hazard to safety-related equipment. As a minimum the following subjects should be covered:
(3) Most favorable direction from which to attack a fire in each area, in view of the ventilation direction, access hallways, stairs t.. d doors which are most likely t'
to be fire-free, and the best station or elevation for fighting the fire.
A specific identification system l
shall designate all hallways, stairs, doors, fire equipment and system control locations, and other items described in the fire fighting procedures. This identification t
should be used in the procedures and the corresponding plant items should be prominently narked so that they can be recognized in din light. All access and egress routes that involve locked doors should be specifically identified in the procedure with the appropriate precautions and methods for access specified.
(4) Designation of plant systems that should be managed to reduce the damage potential during a local fire:
8109180342 810825 PDR ADOCK 05000206 k
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location of local and remote controls for such management (e.g., any hydraulic or electrical systems in the zone covered by the specific fire fighting procoJure that could increase the hazards in the area because of over-pressurization or electrical hazards).
(5) tesignation of vital heat-sensitive system components that should be kept cool while fighting a local fire, c itical equipment which are particularly hazardous r
crmbustible sources whould be designated to receive cooling.
(7) Identification radiological and toxic hazards in fire zones.
(8) Ventilation system operation that assures desired plant pressure distribution when the ventilation flow it modified for fire containment or smoke clearing operations.
(9) Operations requiring control room and shift engineer l
coordination or authorization.
(10) Instructions for plant operators and general plant personnel during fire."
2.
Attachment No. 1 " Fire Protection Organization" of the Guidance states:
"The organizational responsibilities and lines of communication pertaining to fire protection should be defined between the various positions through the use of organizational charts and functional descriptions of each position's responsibilities. As a minimni the positions / organizations responsible for the following should be desionated:
f.
The positions which are part of the plant fire brigade (1) The plant fire brigade positions should be responsible l
for fighting fires. The authority and responsibility of each fire brigade position relative to fire protection j
should be clearly defined.
(2) The responsibilities of each fire brigade position should correspond with the actions required by the fire fighting procedures."
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3.
Attachment No. 3 " Control of Combustibles" of the Guidance states:
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__ " Administrative controls should be established to minimize the amount of combustibles that a safety related area msy be exposed to. These controls should be established to govern:
b.
the transient fire loads during maintenance and modifications such as combustible and flamable liquids, wood and plastic products, spilled oil, oil drums, and other combustible materials in buildings containing safety related systems or equipment. This control should require an in-plant review of proposed work activities to identify potential transient fire loads. The onsite staff member designated the responsibility for reviewing work activities for potential transient fire loads should specify the required additional fire protection in the work activity procedure.
When the transient fire load causes the total fire load to exceed the capabilities of existing suppression systems and equipment, additional portable suppression equipment should be brought into the area."
4.
Attachment No. 4 " Control of Ignition Sources" of the Guidance states:
" Administrative controls should be instituted to protect safety-related equipment from fire damage or loss resulting fron work involving ignition sources, such as welding, cutting, grinding, or open flame work;...
All cutting, welding, grinding or open-flame work should a.
be authorized by the responsible foraman or supervisor through a work permit...
l b.
Befora issuing the permit, tha responsible foreman or supervisor should physi ally survey the area where the work is to be performed."
y Contrary to the above, on July 17, 1981:
1.
No written strategies existed for the following safety related areas and areas presenting a hazard te safety-related equipment:
Control Room; 480 volt Switch Gear Room; D. C. Switch Gear Room and Battery Room; Auxiliary Buildir.g; Turbine Building Upper Elevation and, East, West, South Lower Elevation; Diesel Generator Building; Containment; and Yard Area.
In addition, the fire fighting strategies that had been prepared for two areas were incomplete. The strategies for these two areas (Turbine Lube 011 Reservoir Area and 4 KV Room) are contained in Emergency Procedure 301-VIII-1.10, but these strategies do not address paragraphs d(3), d(4), d(5), d(7), d(8), d(9), d(10) of Attachment 5 to the Guidance. Also paragraph ri(F of Attachment 5 is only
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partially addressed in these two strategies.
In particular, the special duties of fire hose laying, applying extinguishing agent to the fire, advancing support supplies to the fire scene
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and comunications with the Control Room are not addressed.
2.
No documatation was identified which fully addressed the authority
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and responsibility of all members of the Fire Brigade individually by position. Also, the responsibilities of each fire brigade position relative to the actions required by the fire fighting procedure: were seriously deficient.
3.
No a.dministrative controls existed which required an in-plant review by an onsite staff member of proposed work activities to identify potential transient fire loads and needed additional fire protection.
4.
No administrative controls existed for non-open flame cutting and grinding. Also procedure S01-M-105 " Fire Prevention During Open Flame processes" and Station Order S-A-2 " Fire Protection" do not require a physical survey by the responsible foreman or supervisor.
of the work area prior to issuing the oermit to allow comencement of the work.
The above items taken together constitute a Severity Level IV Violation (SupplementI).
Pursuant to the provisions of 10 CFR 2.201 the Southern California Edison Company is required to submit to this office within twenty-five days of the date of this Notice, a written statement or explanation in reply, including:
(1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further items of noncompliance; and (3) the date when full compliance will be achieved.
Under the authority of Section 182 of the Atomic Energy Act of 1954, as amended, this response shall be submitted under oath or affirmation.
C.4 QQ, AUG 2 51981 g
Dated
@affee,(Reactor I specpr
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