ML20031F672
| ML20031F672 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 09/25/1981 |
| From: | Papay L SOUTHERN CALIFORNIA EDISON CO. |
| To: | Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20031F668 | List: |
| References | |
| NUDOCS 8110200285 | |
| Download: ML20031F672 (8) | |
Text
a 9
EECElVED
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h5 Southern California Edison Compan,n v..
r A O. BOX 800 2244 WALNUT GROVE AVENUE ROSEMEAD, CALIFORNIA 91770 p pg September 25, 1981
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U.S. Nuclear Regulatory Commi ssion Office Of Inspection and Enforcement Regi on V 1990 North California Boulevard Suite 202, Walnut Creek Plaza Attention:
Mr. R. H. Engelken, Director DOCKET No. 50-206 SAN ONOFRE - UNIT 1
Dear Sir:
Your letter of August 25, 1981 forwarded IE Inspection Report No. 50-206/
81-25 and a Notice of Violation resulting from the July 13-17, 1981 routine surveillance.
Enclosure (I) of this letter provides our response to the Notice of Violation contained in Appendix A of the subject report.
I trust the enclosure responds adequately to all aspects of the Violation. If you have any questions or if we can provide additional information, please let me know.
Subscribed on the J[
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Subscribed and sworn to before me th)s j[. day of 2bif/E FU,L,1981.
~m, kkf k lIk-Notary Public j ~ and for the County
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of Los Angeleg State of California Enclosure I L. F. Miller (NRC Site Inspector - San Onofre Unit 1) cc:
8110200285 811013 PDR ADOCK 05000206
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8 B
ENCLOSURE Response to Notice of Violation Identified in Appendix A To NRC Inspection Report No. 50-206/81-25.
ITEM License No. DPR-13 section 3.H. " Fire Protection", last paragraph, 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, " Administrative Controls" of the SE states in part, "We have subsequently recommended that the licensee's administrative controls follow the NRC guidelines set forth in " Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls and Quality Assurance." (hereafter referred to as the Guidance)..."During the site visit ev.it meeting on July 13, 1978, the licensee accepted the staff positions on administrative controls."
1.
Attachment No. 5 " Fire Fighting Procedures" of the Guidance states: The fire fighting procedures should ident* fy:
"d.
The strategies established for fightina fires in all safety-related areas and areas presenting a hazard to safety-related equipment. As a minimum the following subjects shoild be covered:
(3)
Most favorable direction from which to attack a fire in each area, in view of the ventilation direction, access hallways, stairs and doors which are mcst likely to be fire-free, and the best station or elevation for fighting the fire. A specific identification system shall designate all hallways, stairs, doors, fire equipment and system control l ocati ons, and other items described in the fire fighting procedures. This identification should be used in the procedures and the corresponding plant items should be prominently marked so that they can be recognized in dim 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 shoula oe managed to reduce the damage potential during a iocal fire; location of local and remote controls for such management (e.g., any hydraulic or electrical systems in the zone covered by the specific ? ire fi ghting procedure that could increase the hazards in the area because of over-pressurization or electrical hazards).
8 9
RESPONSE TO NOTICE OF VIOLATION ENCLOSURE PAGE ?
Part 1 (cont'di:
(5)
Designation of vital heat-sensitive system compnnents that should be kept cool while fighting a local fire. Critical equipment which are particularly hazardous combustible sources whould (SIC) be designated to receive cooling.
(7)
Identification [of] (SIC) radiological and toxic hazards in fire zones.
(8)
Ventilation system operation that assures desired plant pressure distribution when the ventilation flow is modified for fire containnent or smoke clearing operations.
(9)
Operations requiring control room and shift engineer 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 thrcugh the use af organizational charts and functional descriptions of each position's responsibilities.
As a minimum the positions / organizations responsible for the following should be designated:
f.
The positions which are part of the olant fire brigade (1)
The plant fire brigade positions should be responsible for fighting fires.
The authority and responsibility of each fire brigade position relative to fire protection should be clearly defined.
(2)
The responsibilitits of each fire brigade position should correspond with the actions required by the fire fignting procedures."
3.
Attachment No. 3 " Control of Combustibles" of the Guidance states:
" Administrative controls should be established to mimimize the amount of combustible 3 that a safety related area may be exposed to.
These controls should be established to govern:
dESPONSE TO N011CE OF VIOLATION ENCLOSURE PAGE 3 PART 3 (cont'd):
b.
the transient fire loads during maintenance and modifications such as combustible and flammable liquids, wood and plastic products, spilled oil, oil drums, ar.d other combustible materials in buildings containing safety related systens 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 activi ties 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 from work involving ignition sources, such as welding, cutting, grinding, or open flame work;...
a.
All cutting, welding, grinding or open-flame work should be.
authorized by the responsible foreman or supervisor t h rou gh a wo rk permi t...
b.
Before issuing the permit, the responsible foreman or supervisor should physically survey the area where the work is to be performed."
Contrary to the above, on July 17, 1981:
1.
No written strategies existed for the following safety related areas and areas presenting a hazard to safety-related equipment:
Control Room; 480 volt Switch Gear Room; D.C. Switch Gear Room and Battery Room; Auxiliary Building; 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 Oil Reservoir Area and 4 KV Room) are contained in Emergency Procedure S01-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 to the Guidance. Also paragraph d(6) of j
RESPONSE TO NOTICE OF VIOLATION ENCLOSURE PAGE 4 CONTRARY (cont'd): is onl" partially addressed in these two strategies.
In particular, the special duties of fire hose laying, applying extinguishing agent to the fire, advar.cing support supplies to the fire scene and canmunications with the Control Room are not addressed.
2.
No documentation was identified which fully addressed the authority 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 procedures were seriously deficient.
3.
Nn adminstrative controls existed which required an in-plant review by an onsite staff member of proposed work activities to identify potantial 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 permit to allow comrenc.ement of the work.
The above items taken together constitute a Severity Level IV Violation (Supplement I).
(sic)
RE SPONSE 1.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVE 0 Subsequent to the July 17, 1981 exit interview for the subjact inspection, a thorough review of documentation applicable to fire protection administrative control requirements for Unit 1 was conducted. Additionally, Quality Assurance Audit Report i
S01-33-81, issued August 28, 1981, inspected the current Fire Protection Program in accordance with Technical Specification 6.5.2.8 (G) to verify compliance of Station Procedures and practices relative to the requirements of " Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls and Quality Assurance" and 10 CFR 50 Appendix R, sections 111 G, J and O.
It has been determined that several portions of the
RESPONSE TO NOTICE OF VIOLATION ENCLOSURE PAGE 5 CORRECTIVE STEPS TAKEN (cont'd):
program, including those identified by Notice of Violation, require improvement in order to fully comply with the guidance referenced within and provided by License Condition 3.H and assure effective administrative controls in all required areas.
Six Corrective Action Requests issued as a result of the Quality Assurance audit have been responded to and are in the process of being impl emented.
As a result of the identified problems, steps to initiate a systematic program to review the administrative portions of the Fire Protection Program and correct the deficiencies identified have been taken.
The revicw is an initial part of the preparation of a Fire Protection Plan with associated implementing procedures, similar in intent to the now existing Security and Emergency Plans.
2.
CORRECTIVE STEPS WHICH WILL BE TAKEN The San Onofre Fire Protecton Plan will be a single source document encompassing the requirements and providing broad guidance for the direction of fire protection and related activities within the facility, The plan will consolidate the canmitments, define an expanded organization, and establish administrative controls under which the program will be conducted.
Implementing procedures will be used to provide detailed guidance for actions required by the plan.
A listing and description of the procedures necessary fo-implementation will he generated during the preparation of the Fire Protection Plan. Existing Unit 1 procedures will be evaluated for adequacy and utilized whenever appropriate. The generation of adoitional procedures found to be necessary will be initiated once the scope and direction of the additional procedures is defined.
Training for the Plan and the associated implementing procedures will be prnvided to Station personnel.
Any additional deficiencies in the existing Fire Protection Program found during the review and/or preparation of the Plan will be documented and identified to the Quality Assurance Organization.
All items identified in the subject Notice of Violation will be addressed in the plan and asscciated procedures.
r RESPONSE TO NOTICE OF VIOLATION ENCLOSURE PAGE 6 The following interim actions will be taken to address the specific concerns expresseo in the Notice of Violation:
1.
Strategies for fighting fires in the various_ plant areas will be discussed in the monthly training sessions attended by members of the Station Fire Brigade.
The discussions will be conducted by an individual qualified as a fire fighter and knowledgeable of the specifics of the Unit I l ayou t.
2.
The authority, responsibility and duties of the members of the Fire Brigade in responding to and combating a fire emergency will be discussed in the training sessions.
As nore extensive written fire fighting strategies are developed, the actions required by individual Fire Brigade members under the circumstances will be procedurally defined and discussed at the meetings.
3.
The Fire Canmittee Chairman will be required to review proposed work activities in the plant on a daily basis in order to identify potential increases in fire loading and the need for additional fire protection to maintenance and construction personnel.
Station Order S01 - A-16, "Fi re Committee", will be revised to reflect the above and to increase the frequency of fire hazard inspections by the Fire Committee Chairman from monthly to weekly.
4 Maintenance Procedure 501-M-105, " Fire Prevention During Open Flame Processes" will be revised to include cutting and grinding on the Flame Permits issued for work inside the pl ant.
Station Order S-A-2, " Fire Protection", will be revised to require a responsible individual to inspect the work area prior to commencing activities which require a Fl ame Permit.
5.
Station Order S-A-2, " Fire Protection", currently requires in Section VI, "Any operations or outages that will render any installed fire protection system incapable of performing all of its intended functions will be coordinated through the Fire Committee Chairman or his designated representative." This responsibility includes inspecting the adequacy of compensatory measures, including assurance that non-qualified fire hoses have not been used for back up fire protection.
l e
RESPONSE TO NOTICE OF VIOLATION ENCLOSURE PAGE 7 6.
In order to tighten existing administrative controls over fire equipment outages, this responsibility will be additionally inserted into Station Order S01-A-16, " Fire Canmittee. " Operating Instruction 501-14-12, " Equipment Control Implementation", is currently undergoing extensive revision, and will also require the Fire Cammittee Chairman to coordinate fire equipment outages and inspect the compensatory measures. Operating Instruction 501-11-1,
" Fire Water and Foam Systems Operations", Section A, will be revised to define the qualifications for fire hoses used for back up fire protection.
3.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED A comprehensive fire protection program to bring San Onofre Unit 1 into full compliance with License Condition 3.H and which will iddress all of the concerns expressed by the Nuclear Regulatory Commission and is in the initial stages of development.
The interim measures discussed above will be implemented as follows:
interim actions 1 and 2 by October 31, 1981 with stratagies discussed for major saftey related equipment by February 1,1982; interim actions 3, 4, 5 and 6 completed by October 31, 1981. The Fire Protection Plan and associated impl ementing procedures will be completed June 1,1982.
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