ML20031A063
| ML20031A063 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 08/24/1981 |
| From: | Chaffee A, Zwetzig G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20031A061 | List: |
| References | |
| 50-206-81-25, IEB-80-06, IEB-80-6, NUDOCS 8109180343 | |
| Download: ML20031A063 (8) | |
See also: IR 05000206/1981025
Text
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U. S. NUCLEAR REGULATORY C0fEISSION
OFFICE OF INSPECTION AND ENFORCEMENT
REGION V
Reprt No. 81-25
Docket ?!o. 50-206
License No. DPR-13
Safeguards Group
Licensee:
Southern California Edison Comoany
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P. O. Box 800
2244 Walnut Grove Avenue
Rosemead. California 91770
Facility Name: San Onofre Unit 1
Inspection at: San Onofre. california
Inspection conducted: ,1olv 13-17. los1
Inspectors:b
Tc/p
VI
A
A. Cha(fee, Reactor Inspector
'Dat6 Signca
Date Signed
[/ad140/4/,/9//
Approved by:
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G. 'fwetzHJ, COied, Reactor Projects Section #1
v Date Sfgned
Reactor Operations Projects Branch
Sunraary:
Insoection on July 13-17, 1981 (Report No. 50-206/81-25)
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Areas Inspected: Routine, unannounced inspection of licensee's Fire Protection /
Prevention Program, IE Bulletin Followup, and Followup on Significant Event
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that Occurs During Inspection. This inspection involved 40 inspector-hours
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onsite by one NRC inspector.
Results: Of the three areas inspected, no items of noncompliance were
identified in two areas; one item of apparent noncompliance (fcilure to
establish required administrative controls for fire protection, paragraph 3B)
was identified in one area.
8109180343 010825
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PDR ADOCK 05000206
RV Fonn 219 (2)
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DETAILS.
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1.
Persons' Contacted
- E. Gault, Clerk-Typist
- D. Nunn, Manager, Quality Assurance
- B. Katz, Assistant Station Manager, Technical
- H. Morgan, Assistant Station Manager, Operations
- J. Curran, Plant Manager
- F. Briggs, Compliance Engineer
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- J. Dunn, Project Ocality Assurance Supervisor
- J. Haynes, Manager, Nuclear Operations
- L. Papay, Vice President, Advanced Engineering
- J. Reeder, Supervisor of olant Coordination, Unit 1
- C. Seward, Fire Marshall, Unit 1
R. Neal, Engineer
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- Denotes those persons who attended the exit interview.
Also present at the exit interview was the NRC Recident Inspector,
L. Miller.
2.
Follow-up on IE Bulletin 80-06 (Engineered Safety Feature (ESF) Reset
Controls) (0 pen)
The inspector reviewed the following:
a)
Licensee response dated June 9, 1980.
b)
Cold S.I.S and Loss of Offsite Power Test conducted on May 9,
1981 (procedure S01-12.8-2).
Based on the above review and discussions with licensee personnel the
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inspector noted the following:
a)
The licensee's response dated June 9,1980 appears to adequately
address items 1, 3 and 4 of the Bulletin.
b)
The licensee performed the test required by item 2 of this Bulletin
on May 9, 1981.
This test demonstrated that all systems and components
responded appropriately except for valves M0V 11008, C and D,-
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which returned to their normal mode upon ESF reset. The original
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drawing review done in accordance with Item 1 of the Bulletin
failed to reveal this behavior.
Further review performed after
the test verified that the valves behaved as indicated in the
existing drawings.
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As presently designed, the valves automatically shift charg'ng
pump suction to the Volume Control Tank from the Refueling Water
Storage Tank upon ESF reset. This results in the chargint pumps
drawing from an unborated water source rather than a bore.ced
source. The licensee has provided administrative contrels to
prevent this shift until equipment modifications can be made.
(This control consists of a procedure change which requires the
valves to be placed in the manual mode prior to resetting ESF.)
The licensee will submit a followup report describing the results of
this test and proposed corrective action for the identified problem.
This item will be reviewed further at a subsequent inspection.
3.
Fire Protection /Preverition Program
A.
Document Review
The inspector reviewed the following documents:
1)
License No. DPR-13, paragraph 3.B, Technical Specifications
(applicable sections) and paragraph 3.H " Fire Protection".
2)
Fire Protection Safety Evaluation Report, section 6 dated
July 19, 1979 (Note: This was appended to amendment 44
to License No. DPR-13).
3)
Fire Protection Program Reivew, BTP APCSB 9.5-1, San Onofre
Nuclear Generating Station Unit one, dated March 1977.
4)
Nuclear Plant Fire Protection Functional Responsibilities,
administrative Controls and Quality Assurar.ce; as included
in NRC letter dated August 19, 1977 to the licensee.
5)
Division Order D-A-13, " Fire Protection", rev. O, dated
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April 23, 1981.
6)
Station Order S-A-2, " Fire Protection", rev. 22, dated February 1,
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1980, through PCN 4.
7)
Station Order S-A-10, " Station Inspections and Housekeeping"
rev. 9, dated February 1,1980.
8)
Maintenance Procedure S-I-1.13, "New Cable Installations
Through Existing Flame Barriers", rev. 3, dated October 4,1978.
9)
Station Order S01-M-105, " Fire Prevention During Open Flame
Processes", rev. 3, dated July 22, 1980.
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10) Station Order, S01-A-16, " Fire Cuanittee", rev. O, dated
February 24, 1981.
11) Station Order, 501-A-134, " Fire Brigade Training and Retraining",
rev. O, dated June 27, 1980.
12) Emergency Procedure, S01-VIII-1.10, " Fire Fighting" rev.1,
dated April 24, 1981.
13) Operating Instruction, S01-7-1, " Fire Water System Operation",
rev. 10, dated June 27, 1980.
14) Operating Instruction, S01-11-1, " Fire Water and Foam Systems
Operation", rev. O, dated March 16, 1981.
15) Nuclear Training Division Memorandum 6-81, " Fire Brigade
Member Training Program", dated May 1,1981.
16) Emergency Procedure, S01-VIII-1.6, " Plant Evacuation and
Accountability", rev. 1, dated March 25, 1981.
17) Operatina Tr.struction S01-11-2, "4KV Room Halon System Operations",
rev. O, dated January 28, 1981.
18) Operating Instruction S01-11-3, " Portable Fire Extinguishers",
rev. O, dated April 24, 1981.
19) Operating Instruction, S01--11-4, AWS Building Halon System
Operation, rev. O, dated March 31, 1981.
20) Nuclear Training Division Training Memorandum, 9-81, " General
Employee Orientation Training", dated May 21, 1981.
B.
Results of Document Review
Based on the above document review and discussions with licensee
personnel th inspector determined that the licensee's administrative
controh for fire protection are not in accordance with condition
3.H of the facility license.
License condition 3.H requires that adminstrative controls for
fire protection be implemented in accordance with the controls
identified in Section 6 of the Fire Protection Safety Evaluation
Report. This section requires administrative controls be implemented
in accordance with " Nuclear Plant Fire Protection Functional
Responsibilities, Administrative Controls and Quality Assurance"
(hereafter referred to as the Guidance) which was included in
an August 19, 1977 letter from the NRC to Southern California
Edison.
Comparing the licensee's administrative controls for
fire protection to those listed in the Guidance, revealed the
following apparent omissions in'the licensee's program:
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1)
The licensee has not developed fire fighting strategies for
all safety related areas and areas presenting a hazard to
safety-related equip e nt.
In p' articular the following areas
have no writter fire fighting strategies: Control Roor6
480 Volt Switch Gear Room; DC Switchgear Room and Battery
Room; Auxiliary Building; Turbine Building Upper Elevation
an East, West, South Lower Elevation; Diesel Generator
Building; Containment; and Yard Area.
2)
The only areas that do have fire fighting strategies, (which
are cont 9ed in Emergency Procedure S01-VIII-1.10) are
the Turbirc Lube 011 Reservoir Area and the 4KV Room.
However
the strategies for these areas are not complete.
In particular,
the subjects listed in paragraphs d(3), d(4), d(5), d(7),
d(8), d(9) and d(10) of Attachment 5 to the Guidance are not
addressed.
In addition, the subject matter of paragraph d(6) of Attachment 5
to the Guidance, although partly addressed, is also not
complete for those strategies that do exist.
3)
The authority and responsibility of each fire brigade position
relative to fire protection are not clearly defined as required
by paragraphs f(1) and (2) of Attachment 1 to the Guidance.
4)
The administrative controls for combustible waterial do
not reqrire in-plant review of proposed work activities
to identify potential transient fire loads as required by
paragraph b of Attachment 3 to the Guidance.
(Note: This
function is required to be assigned to an onsite staff memter
who should also specify the required additional fire protection
in the work activity procedure, after taking total plant
fire load into account.)
5)
The licensee's administrative controls for ignition sources
are not in accordance with the requirements of Attachment 4
to the Guidance. Specifically, Station Order S01-M-105
" Fire Prevention During Open Flame Processes" and Staticn
Order S-A-2 " Fire Protection" which are the only identified
procedures in this area, do not address grinding or non-> pen
flame cutting (e.g. by cutting wheel). Also the licensee's
procedure does not require a physical survey of the work
area by the responsible foreman or supervisor prior to issuing
a permit.
C.
Sumary Concerning Apparent Items of Noncompliance
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Each of the items listed above is an apparent item of noncompliance.
However, all of the items appear to stem from a lack of understanding
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on the licensee's part of license condition 3.H.
In mitigation,
it is noted that the documentation establishing these requirements
is somewhat complex.
In light of the connon basis for these
omissions, it is the inspector's opinion that these items taken
together constitute one item of apparent noncompliance (0I-81-
25-01).
D.
Other Concerns
The above review of the licensee's administrative controls with
respect to the-Guidance also revealed the following concerns:
1)
The Guidance requires'the. licensee to make " provisions for
training offsite fire department personnel in basic radiation
principles, typical radiation hazards, and precautions to
be taken in a fire-involving radioactive materials in the
plant." The licensee. stated in letter dated May 19, 1978
that "In the event of'a fire e ergency, all offsite fire
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department personnel would be escorted by an individual
knowledgeable in basic radiation principles, typical radiation
hazards, and precautions to be taken in a fire involving
radioactive materials in the plant." This approach was
stated to be used in place of the above requirement.
In
a letter dated June 21, 1978, the NRC appears to accept this
position.
However, at present it does not appear that the
licensee is organized to implenent either method.
The licensee
has stated he will reevaluate his program to assure compliance
with one of these methods (01-81-25-02).
2)
Attachment No. I to 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
minimum the positions / organizations responsible for the
following should be designated"...
"c.
The onsite management position responsible for the
overall administration of the plant operations and emergrncy
plans which include the fire protection and prevention
program and which provides a single point of control
and contact for all contingencies."
This requirement is not clearly addressed in the licensee's
documentation.
Th'.s item was also identifiei
4- Licensee
Corrective Action Request (CAR S01-P-404).
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Figure 6.2.3.1 of the Technical Specifications suggests
that possibly the Industrial Safety and Fire Protection
(ISFP) Supervisor is the position with the responsibilities
and' authorities descriMd above.
However, Station Order
- S-A-2, " Fire Protection" which is the controlling station
document in this area, addresses the responsibilities and
authorities of onsite positions but makes no mention of the
ISFP Supervisor.
This was discussed with the ISFP Supervisor who agreed that
his authority and responsibilities needed definition in
S-A-2.
The licensee comitted to revise his procedures
as required by paragraph C of Attachment 1 to the Guidance.
This problem is to be addressed and corrected as part of
a comprehensive fire protection program upgrade.
(Note:
This upgrade will incorporate corrective actions to respond
to the licensee's Q. A. Audit concerns and the Inspector's concerns.
The overall intent of this program is to bring all of the
fire protection program into full agreement with the Guidance
and all other regulatory requirements. The licensee is
performing a preliminary evaluation prior to comitting to
a date for completion of this program upgrade (01-81-25-03).
E.
Facility Tour _
During a tour of the facility the inspector noted that two non-
qualified fire hoses were being used for backup fire protection
of both diesel generator rooms. The inspector determined that
these hoses were Bechtel construction hoses which had no documented
hydrostatic tests (which qualified them for fire service) available
for inspector raiew. This occurred during the period when the
sections of the fire main supplying all normal fire suppression
capability to the diesel generators was out of service to allow
Bechtel installation of a TMI modification.
This condition was
brought to the attention of the licensee, who promptly replaced
the hoses in question. The licensee further committed to provide
appropriate administrative controls in this area within 30 days.
(0I 81-25-04)
F.
Overall Assessment
Despite the previously noted omissions and concerns, the inspector
notes that significant improvements have been made in the licensee's
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fire protection program since issuance of the Fire Protection
Safety Evaluation Report.
The most significant improvements have
occurred in the area of hardware additions (e.g. fire walls,
halon e
,etc). The licensee has also increased his fire
protection staff recently by hiring a Fire Protection Supervisor.
However, it appears additional staff is needed to allow further
development of the program in accordance with the Guidance in
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a timely fashion. Also once the program is fully developed, a
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suitable staff will be needed to allow proper administraticn
of the program. The licensee has budgeted additional personnal
for this area for 1982.
However, based on the inspecticn results
it appears that the staff increases should be. expedited. The
licensee has committed to reevaluate his fire protection program
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needs in light of the Guidance.
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4.
Followup on Significant Event that Occurs During Inspection - Fire
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in Diesel Generator No. 1
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During the course of this inspection, a fire occurred involving Diesel
Generator No. I and the inspector observed the licensee's response
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to this event.
It appeared that the coordinated effort between the
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Control Room operators in securing diesel promptly and the rapid response
of the Fire Brigade was instrumental in limiting the fire to only
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7 minutes, and thereby greatly reducing the damage to the diesel.
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At the time of the fire the water deluge system and normal backup
fire hose station inside the diesel generator room were out of service
due to TMI work.
In place of these systems the licensee had established
a fire watch, which provided surveillance for both diesel generator
rooms, and had run fire hose from an operational fire hydrant to each
diesel generator room.
5.
Exit Interview
The inspector met with licensee representatives denoted in paragraph-1
an July 17, 1981.
The results of the inspection were discussed and
the licensee made the commitments described in paragraphs 3E and 3F.
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