ML20081K944
| ML20081K944 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 03/28/1995 |
| From: | Marsh W SOUTHERN CALIFORNIA EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9503290351 | |
| Download: ML20081K944 (2) | |
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,y m[f Southem Califomia Edison Ccmpany 23 PARKER STREET IHVINE, CALIFORNIA 92718 March 28, 1995 WALTER C. M 4HSH m,,xm J MAC4AC.E M OF PAJCL,AR Mf.C) M.ATORY AFF AtRS (714)454 4403
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U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C.
20555 Gentlemen:
Subject:
Docket Nos. 50-361 and 50-362 Fire Brigade Administrative Staffing Level San Onofre Nuclear Generating Station Units 2 and 3
Reference:
Letter from Donald E. Hickman (NRC), to Mr. Kenneth P. Baskin (SCE) and Gary D. Cotton (SDG&E) dated March 16, 1988;
Subject:
Updated Fire Hazards Analysis Evaluation for San Onofre 2 and 3 The referenced letter indicated that the San Onofre Nuclear Generating Station (SONGS) fire trigade is composed of "7 persons per shift and.that no offsite response will reduce personnel below the 5 persons required by the technical specifications." This letter is to inform you of a change to our fire brigade administrative staffing limit from seven persons to six persons per shift.
San Onofre uses a full time fire department, including licensed emergency medical technicians (EHis) to fulfill the Technical Specification (TS) fire brigade requirement.
During NRC inspections in the late 1980s, concern over shift staffing levels arose due to a mutual aid agreement that Edison has with a local fire department. The concern was that this agreement could cause the SONGS fire department staffing to be reduced below the TS liriit if fire fighters were sent to support off-site mutual aid requests. This was resolved by implementing an administrative limit to ensure that the fire department on-shift staff would not be reduced below the TS minimum of five persons to support off-site mutual aid requests.
As mentioned, we have changed our administrative staffing from seven to six j
persons per shift.
This change to the administrative staffing limit has caused us to examine our on-site medical aid policy with regard to TS compliance. The EMTs in the fire department respond to on-site events that require medical attention.
If a person requires advanced medical care, two EMTs from the fire department may transport the injured party to a local area hospital in the fire department ambulance.
If the fire department staffing level is initially at the new administrative minimum of six people, the i
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09cument Control Desk' dispatch of two EMTs to the hospital will reduce the number of on-site fire brigade personnel to four people. The SONGS 2 & 3 TSs allow for the unexpected absence of fire brigade personnel. Specifically, Administrative Section 6.2.2 states:
" Fire Brigade composition may be less than the minimum require-ments for a period of time not to exceed two hours in order to accommodate unexpected absence provided immediate action is taken-to fill the required positions."
The requirements of Technical Specification 6.2.2 would be met in this situation since the transportation of a person requiring advanced care is considered an " unexpected absence" and because the ambulance would be expected to return to the site before an immediate recall of an off-shift fire fighter could restore on-site shift manning.
The ambulance would be in radio contact and within approximately 30 minutes driving time to the site.
If for any reason it appears that the ambulance will be detained, Edison will take immediate action to recall additional fire fighting personnel. In no case will we be below minimum on-site shift staffing in excess of two hours.
If you have any questions, please contact me.
Sincerely,
[h0 cc:
L. J. Callan, Regional Administrator, NRC Region IV A. B. Beach, Director, Division of Reactor Projects, Region IV K. E. Perkins, Jr., Director, Walnut Creek Field Office, NRC Region IV J. A. Sloan, NRC Senior Resident Inspector, San Onofre Units 2 & 3 M. B. Fields, NRC Project Manager, San Onofre Units 2 and 3
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