ML20198P736
| ML20198P736 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 01/16/1998 |
| From: | Tulon T COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-456-97-16, 50-457-97-16, NUDOCS 9801220226 | |
| Download: ML20198P736 (15) | |
Text
{{#Wiki_filter:Onnmonwc lth 14hwn Oppan) liraklwani Generating Station 'O Itoute *I, Ikst Hi lira rtille. Il 60id?%I9 Tel HI5 4% biol January 16,1998 Document Control Desk US Nuclear Regulatory Commission Washington, D.C, 20555 Subject Reply to Notice of Violation NRC inspection Report 50-45S(457)/97016 Braidwood Nuclear Power Station Units 1 and 2 NRC Docket Numbers 50-456 and 50-417 i
Reference:
G. E. Grant letter to T. J. Tulon dated December 17,1997, transmitting Notice of Violation fro,a inspection Report 50-456(457)/97016 An Inspection Report documenting observations made during a six week period which ended on November 3,1997, was transmitted with the Reference letter. A Notice of Violation (NOV), which included six Severity Level IV violations, was also included as part of the inspect:en Report. Comed's response to these violations is documented in the attachment to this letter. Many of the violations issued during this inspection period were the result of programmatic weaknesses which the station has been working to resolve. Performance with respect to cart storage, scaffold control, combustible control, and Radiation Protection work practices have all received increased attention. At this time, the focus in these areas is to ensure the guidance given to the workers is clear, proper training is administered, and parformance is monitored, Braidwood Station believes that the actions currently being pursued will improve performance. The following commitments were made in the attachment to this letter: A revision to the reportability guidance was initiated to accurately reflect the provisions of 10 CFR S0.72 for the reporting of these actuations. Additionally, a review of the reporting guidance has been undertaken to confirm that the guidance is consistent with all reportinc ~ ?quirements of 10 CFR 50.72. This review is ongoing. / h'C ' il 9901220226 900116 1 PDR ADOCK 05000456 y( G PDR 4 ni b V U.L lli!!ill llIllfillli A Unicum Contpary
o Document Control Desk Page 2 January 16,1998 An expanded pre-job briefing will be conducted with contractor personnel prior to e the use of the revised freeze seal procedure to discuss the changes and individual responsibilities. An evaluation of the current logging methods for tracking scaffold structures will be conducted. Results from this review will be communicated appropriately. Existing station guidance on control of carts and other portable equipment will be revised to clarify the requirements. Following the procedure / policy revision, appropriate training will be conducted. A task force was initiated to evaluate current processes, procedures, and methods to promote personnel accountability with respect to fire protection issues. The Fire Marshal will review the training provided to contract personnel to identify weaknesses regarding instruction of fire preventinn procedures and requirements. If your staff has any questions or comments concerning this letter, please refer them to Terrence Simpkin, Braidwood Regulatory Assurance Supervisor, at (895) 458-2801, extension 2980. fQ Ti a hy J. Tulon te Vice President raidwood Nuclear Generating Station $60044t doc Attachment cc: A.B. Beach, NRC Regional Administrator, Region ill G.F. Dick, Jr., Project Manager, NRR C.J. Phillips, Senior Resident Inspector F. Niziolek, Division of Engineering, Office of Nuclear Safety, IDNS
i ATTACilMENT 1 REPLY TO NOTICE OF VIOLATION f $0-456:457/97016-011 1. 10 CFR 50.72(b)(2)(ii) states a four hour non-emergency notification to the NRC is required when the following occurs : (ii) Anv event or condition that results in a manual or automatic actuation of any engineered safety feature (ESF), including the reactor protection system, except when: (A) The actuation results from and is part of a pre-planned sequence during testing or reactor operation; (B) The actuation is invalid and; (1) Occurs while the system is properly removed from service; (2) Occurs after the safety function has been already completed; or (3) Involves only the following specific ESFs or their equivalent systemt; (i) 1% actor water c'rean-up system; (ii) Control room emergency ventilation system; (iii) Reactor building ventilation system; (iv) Fuel building ventilation system; or (v) Auxiliary building ventilation system. Contrary to the above, on October 14,1997, a licensee instrument technician made an error when changing setpoints on the Unit 2 containn ent area radiation monitor 2AR11J. The error resulted in a false high radiation alarm and a Unit 2 "A" train containment ventilation isolation. The licensee failed to make a notification to the NRC within 4 hours as required by 10 CFR 50.72 for the ESF actuation involving the containment ventilation isolation. REASON FOR THE VIOLATION As a result of a revision to 10 CFR 50.72, which excluded certain specific engineered safety feature (ESF) systems or their equivalents from the notification requirement, Comed revised it's reportability guidance in June,1994. This revision to the guidance inappropriately excluded Containment Ventilation isolations (CVis) when they were actuated by the area radiation monitor input. CVI actuations in conjunction with a 1
A'ITACitMENT I REPLY TO NOTICE OF VIOLATION (50-456:457/97016-0.1) Safely injection signal continued to be considered reportable. The rationnt? applied to consider a CVI actuated from the area radiation monitor to be not reportat'e was as follows: The actuations excluded from reporting in the revision to 10 CFR 50.72 were attributable to a radiation monitor input, The result of the actuation for the excluded systems was that the process flow path would be isolated or aligned to a filtration system,
- and, The excluded actuations were not attributable to such design basis events as a Loss of Coolant Accident.
The CVI when actuated from the area radiation monitor met these enis;ia, and thus the actuation was judged to be equivalent to the excluded actuations. As a result, this was considered to be not reportable. CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED Because the requirements of 10 CFR 50.72 could not be met, the actuation was reported in accordance with the corresponding provisions of 10CFR50.73. This reporting requirement was met via submission of LER 457-004-00, which was submitted on November 14,1997. This LER was submitted within 30 days from the date of the actuation, thus meeting the time requirements of 10CFR50.73. As interim actions (while the revision to the reportability manualis being pursued), Operations issued a Department Policy Memo to communicate that an actuation attributed to a radiation monitor input is reportable. This was also communicated as part of the Shift Manager's turnover. ACTIONS TAKEN fTO BE TAKEN) TO PREVENT RECURRENCE When it was identified that the reportability guidance was in error, the other affected Comed facilities were notified of the error and advised to not app!, the erroneous guidance to Containment Ventilation Isolation actuations which may be experienced. A revision to the reportab;lity guidance was initiated to accurately reflect the provisions of 10 CFR 50.72 for the reporting of these actuations. Additionally, a review of the reporting guidance has been undertaken to confirm that the guidance is consistent with all reporting requirements of 10 CFR 50.72. This review is ongoing. DATE WHEN FULL COMPLIANCE WAS ACHIEVED Full compliance was achieved upon fulfilling the reporting requirements by submission of LER 457-004-00 on November 14,1997. 2
ATTACHMENT I REPLY TO NOTICE OF VIOLATION (50-4 %:457/97016 4 2)- 2. ' Technical Specification (TS) 6.8.1.a states, in part, that written procedures shall be established, implemented, and maintained covering tN epplicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Regulatory Guide 1.33. Revision 2, Appendix A, Section 9.e, states, general procedures for the control of maintenance, repair, replacement, and modification work should be prepared before reactor operation is oegun. Braidwood maintenance procedure (BwMP) 3300-018," Application of Liquid Nitrogen Freeze Seal to all Piping," Revision SE1, Step F.4.a. requires a maintenance supervisor to obtain shift supervisory permission to start the freeze.- Step F.4.e requ'rer a supervisory signature for the evaluation of freeze plug integrity. Step FA.f.1 requires the recording of temperature readings every ten minutes on a freeze seallog (Attachment 2 to the procedure). Step F.4.f.2 requires that frequent oxygen readings be obtained at the work location and near the floor. Step F.4.g requires an individual to acknowledge the completion of steps F.4.a through F.4.g by providing their initials. Steo F,5.a requirss a supervisory signature for the proper maintenance of the freeze seal. Contrary to the above, as of October 1,1997, contractor personnel did not make the above required signatures prior to mechanics breaching the essential service water system, did not utilize Attachment 2 of the procedure to record required temperature readings, and did not obtain required oxygen readings. REASON FOR THE VIOLATION On October 1,1997, a freeze seal was initiated to allow 2SX2102 to be repaired / rebuilt using BwMP 3300-018," Application of Liquid Nitrogen Freeze Seal to all Piping." During the evolution, examples of procedure adharence deficiencies were identified. The procedure adherence concems were due to the lack of rigorous execution of the documentation requirements specified in the procedure. CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED Immediately after the event, a meeting was held with personnel representing the work crew, Contractor supervision, th Operations Field Supervisor, the job Maintenance Supervisor, and a Comed Construction Supervisor. During the meeting, the event circumstances were assessed and procedure adherence standards were reinforced. The assessment determined that the failure to properly sign off the steps indicated above had no impact on the outcome of the job or the safety of the workers. 3
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ATTACHMENT I.. REPLY TO NOTICE OF VIOLATION LtdE457/97016-02) ACTIONS TAKEN (TO BE TAKEN) TO PREVENT RECURRENCE BWVP 3300 018 was revised to enht nce clarity and address concerns identified as a -l result of this event. An expanded : se-job briefing will be conducted for contractor-personnel during the upcoming refueling outage prior to the use of the revised procedure to discuss the changes and their respective responsibilities. DATE'WHEN FULL COMPLIANCE WAS' ACHIEVED Full compliance was achieved when the meeting was conducted with the involved individuals to discuss procedure standards and the identified procedure deficiencies, and the evaluation of the performed procedure was done which determined the actions had no adverse impact on the freeze seal job. f 4
ATTACl! MENT I REPLY TO NOTICE OF VIOLATION (50-45&457/97016-0M ' 3. 10 CFR Part 50. Appendix B, Criterion V, states, in part, activities affecting quality shall be prescribed by documented instructions, procedures, and i drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these procedures. BwMP 3300-025, " Erection, inspection, Use, and Dismantling of Scaffolding, Ladders and Temporary Barriers," Revision 3, Step 1.c.1, Scaffold Request Form (BwMP 3300-025A1), required the shift manager / designee to review the scaffold for impact on plant operations and equipment and to note any concems or specialinstructions. Step E.13 of BwMP 3300-025A2 requires that all scaffolds erected in seismic areas have a scaffold request form (BwMP 3300-025A1) posted on the scaffold prior to placing the scaffold in use. The scaffold request form documents that the scaffold was built and inspected to seismic standards. Additionally, Step F,7 of BwMP 3300-025A2 requires all seismic scaffolds to be lotged in the scaffold tmcking program. Contrary to the above, on August 25,1997, scaffolding was erected in a seismic area next to the Unit 2 containment spray additive tank (2CS01T) and was missing the scaffold request form certifying that it met the seismic regirements. On August 28,1937, three scaffolds had been erected in the 1 A/C, diesel oil storage tank room over the 1 A diesel oil storage tank transfer pump and next to the diesel oil storage tanks, all designated as seismic areas, without the required BwMP 3300-025A1 form and without being logged into the scaffold tracking program. On September 8,1997, scaffolding was erected in the Unit 2 main steam pipe tunnel, a designated seismic area, without the required BwMP 3300-025A1 form, and the scaffolding was not Ingged into the tracking program. On September 16,1997, scaffolding was erected in the auxiliary building over the 2B containment chiller, a designated seismic area, without the required BwMP 3300-025A1 form attached. REASON FOR THE VIOLATION The above violation stated that BwMP 3300-025A1, the " Scaffold Request Form," was not attached to tour different scaffold structures. This concern was evaluated, however no cause could be idenlified to explain the missing " Scaffold Request Forms". Several Mechan: cal Maintenance Supervisors were interviewed to assess whether there was a knowledge weakness with respect to the proper use u this form. It was concluded that the supervisors had a good understanding of the requirement. The violation also indicated that information on two scaffold structures had not been logged in the scaffold acking program. These examples were evaluated and it was concluded that the logging methods in place for tracking scaffold structures in the plant may have contributed to the problem. Different logs are accessible to workers, an active log and historicallog files. According to the Scaffold Coordinator, the active log file is where workers should enter new information The historicallog files are available 5
ATTACHMENT I REPLY TO NOTICE OF VIOLATION f 53-456:457/97016 03) ' to workers for retrieving past data. This information.iay not be clearly understood by workers who rely on scaffold log information As a result, log entries for scaffold structures may have been made in an incorrect file. A review of the log files was conducted to determine if log entries for the two identified r?,ncems could be found. Log entries for scaffolds in the Unit One Diesel Oil Storage Tank room were identified on a "Non-outage" scaffold log sheet, however no entry could be found for the identified structure in the Unit 2 Main Steam Tunnel. No-explanation for the missing log entry could be determined. CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED The !dentified scaffold concerns were corrected after they were brought to the station's attention. Due to difficulties encountered during the recently comple'.ed refueling outage, a "Stop Work Order" was issued relative to scaffold construction until the expectations for scaffold control were communicated to involved parties. A_CTIONS TAKEN (TO BE TAKEN) TO PREVENT RECURRENCE Responsibility for the coordination of scaffold issues has been transferred from the Construction Department to the Mechanical Maintenace Department and a Scaffold Coordinator has been assigned as a site contact for scaffold issues. A different process for removing scaffold structures is in place. This process involves the use of Miriimal Work Requests to ensure effective control of timely erection and disassembly of scaffolding in coordination with the weekly work schedule. An evaluation of the current logging methods for tracking scaffold structures will be conducted. Results from this review will be communicated appropriately. DATE WHEN FULL COMPLIANCE WAS ACHIEVED Full compliance was achieved when the paperwork concerns for the specified scaffold structures were resolved, 6
ATTACHMENT ! j REPLY TO NOTICE OF VIOLnTION (50-45&457/97016 04) 4. 10 CFR 50, Appendix B, Criterion XVI, " Corrective Actions," states, in part, that " Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, d6fective material and equipment, and nonconformances, are promptly identified and corrected in the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action is taken to proclude repetition." NRC violation 50-456/96021-01f(DRP); 50-457/96021-01f(DRP) was issued on February 18,1997, to document a violation of station procedures and policies in that the licensee did not control unattended rolling carts and equipment in safety-related areas to prevent damage to safety related equipment during a seismic evcot. In response to the violation, and in order to prevent recurring rolling cart deficiencies, the licenten implemented corrective actions, including issuing written instructions in Braidwood Policy Memo #65, removing rolling carts from the auxiliary building, painting carts remaining in the Auxiliary Building, and attaching brakes or anhoring devices to carts remaining in the Auxiliary Building. Procedure BwAP 10010," Conduct of Station Personnel," Step C.4.d, states, in part, that unattended rolling carts need to be secured so that during a seismic event they will not rollinto a safety-related component. Coneary to the above, between September 15 and October 22, numerous rolling carts were identified in close proximity to safety related equipment without adequate controls to prevent damage to the safety related equipment during a seism : event. Rolling carts were found close to 1RT-AR012, fuel handling builciing incident monitor; 1RT AR014, containment and auxiliary building radiation monitor; ESF [ Engineered Safety Feature) Bus 241, cubicle 21, SX [ essential seMce water) pump 2A breaker; 2SX01PA,2A essential service water pump rnotor; and other stfety-related components. Corrective actions taken in response to NRC violation 50-456/96021-01f(DRP); 50-457/96021-01f(DRP) were not effective in precluding repetition of rolling cart and equipment interference problems. REASON FOR THE VIOL.ATION The control of moveable equipment in the Auxiliary Building has continued to be a problem area at the station. Braidwood Station concluded that problems in this area resulted from personnel not clearly understanding the expectations for proper storage o carts due to insufficient training. Although training was provided to select groups in response to the violation issued in February 1997, it was determined that not all station personnel received this training. Also contributing to the problem was that guidance for control of these items was present in several procedures / policies which were l l 7
ATTACl! MENT I . REPLY TO NOTICE OF VIOLATION -(50-456:457/97016 0 0 considered long and complicated. These problems contfauted to the confusion of the workers who relied on the information. CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED The identified cart and moveable equipment storage concems were promptly currected. A team of personnel from the site representing var ous work groups evaluated the cart i storage problem and identified potential solutions. Examples of potential factors hindering proper cart control that were identified by this team include: workers may not be properly securing carts because they may be confusing the guidance for properly securing carts with rigging guidance, designated cart storage areas may not be large enough, workers may not understand which equipment is safety related (and therefore may not understand where carts and other moveable equipment can be appropriately tied off). Patential solutions identified by this team include: consolidate guidance into one document, attach a copy of guidance to each cart (or abbreviated instructions) so requirements are easily accessible, and train personnel on requirements (initial and periodic). These suggestions will be considered as part of a Root Cause Investigation currently being conducted to evaluate the cart storage concern. As the station has been focusing on developing long term corrective actions, fr areased monitoring of the Auxiliary Building has been conducted by plant personnelin unsure station requirements are satisfied with respect to cart storage. 6CTIONS TAKEN (TO BE TAKEN) TO PREVtiNT RECURRENCE Existing station guidance on control of carts and other portable equipment will be revisod to clarify the requirements. Following the procedure / policy revision, app opriate training will be conducted. Details on previously identified cart concerns and Information on the proper use of carts in the Auxiliary and Fuel Handling Buildings was distributed to station personnel during a Quarterly Human Perforn7nce awareness session coriducted on December 12, 1997. DATE WHEN FULL COMPLIANCE WAS ACHIEVED Full compliance was achieved when the identified cart ctorage concems were resolved and the carts were secured as required. 8
i ATTACilMENT I REPLY TO NOTICE OF VIOLATION Du-45R457/97016-06) 5. TS 6.1.1 states, in part, that procedures for persorsael protection shall be prepared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure. Braldwood radiological procedure BwRP 50101, " Radiological Posting and Labeling Requirements", Revision 7, Step L.3.c, states, that if an area exists which is accessible to individuals and fc which radiation levels could exceed 5 millirem in any 1 hour nt 30 centimeters from the source then post " CAUTION, RADIATION AREA" signs at any entrance to the area. Contrary to the above, on September 26,1997, the inspectors Idertified an area in the auxiliary building, adjacent to the Unit 2A containment spray pump room on elevation 346 that was indicating 12 millirem per hour at 30 centimeters from the source and was not posted as a radiation area. REASON F0R THE VIOLATION The area in question located at the 346' elevation, Unit Two side, had been downposted prior to the discovery of the posting concern identified by the NRC inspectors based on routine surveys and the limited accessibility of the area. A change in plant systems prior to the time the posting concern was recognized had altered the radiological conditions in the area. The area was nut resurveyed until afer tt 4 concern was identified. CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED Radiation surveys were promptly performed in the location of the posting concem. Based on the survey results, the subject brea was irsmediately posted as ' " RADIATION AREA." ACTIONS TAKEN TO PREVENT RECURRENCE Both Unit One and Two survey maps were changed to include the subjec; area. This was done to make Radiation Protection (RP) personnel more cognizant of these areas when parforming radiation surveys. ' A tailgate session was held with RP personnel to rcise their awareness of the area in question and the associated posting requirements. Also included in this session was a discussion emphasizing the need for a questioning attitude when posting and downposting areas. 9
ATTACilMENT I REPLY TO NOTICE OF VIOLATION 0 0-4 %.457/97016-06) fnformation on this posting concern and corresponding corrective actions was submitted to the Training Department for itse in future training as a " Lesson Learned." DATE WHEN FULL COMPLIANCE WAS ACHIEVED Full compliance was achieved when the area in question on the 346' elevation was surveyed and posted as a " RADIATION AREA
- as required.
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ATTACllMENT i REPLY TO NOTICE OF VIOLATION ($0-4$6A)?/97016fL7) 6. 10 CFR 50, Appendix B, Criterion XVI,
- Corrective Actions," states, in part, that
- Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, defic'encies, defective material and equipment, and nonconformances, are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action is taken to preclude repetition."
NRC violation 50-456/97007 03c(DRP); 50-457/97007 03c(DRP) was issued on June 17,1997,i document a violation of station procedures in that the licensee did not control unattended combustible materials in safety related areas. In q response to the violation, the licensee implemented corrective actions, including publishing articles about controlling combustible materials in the daily station newsletter, making presentations to firFt line supervisors to heighten awarenets of fire protection issues, and committing to routinely monitor the plant during outage periods. Procedurer dwAP 110010," Control and Use of Flammable and Combustible Liquids and Aerosols," and BwAP 110011," Fire Prevention for Use of Lumber and Other Combustibles," list the requirements for use of combustible materials in safety related areas of the plant. These requirements include use of approved storage containers for flammable and combustit,le liquids in safety. related structures and u"e of transient firo load permits for combustible materials that must be left unattended in safety related structures. Contrary to the above, between September 10 and October 20, combustible fluids and materials were not adequately controlled in the auxiliary building. Some items identified in non approved safety containers included a 1 gallon glass jar of kerosene, a 1 gallon plastic jug of mineral spirits, and a 1 gallon can of denatured alcohol. There were also two high efficiency particulate air filtere that were specifically detignated by licensee procedures as a major combustible stored in the auxiliary building. Allitems were discovered unattended and without transient fire load permits. REASON FOR THE VIOLATION The primary cause of the flammcble/ combustible material concerns is attributed to the fact that flammable / combustible I quids were being left at the Radiation Protection (RP) zone technicians tool drop-off areas as well as the RP desk at the 401' Auxiliary Building exit during the back shifts when the zone areas were not manned by RP personnel. The RP technicians and the workers leaving the liquids were not aware of the requirement that prohibits flammable / combustible liquids from being le't unattended in the plant unless a permit is obtained as allowed. A root cause analysis conducted to evaluate this concem concluded that workers were leaving the flammable / combustible liquids at the tool drop-off areas during the back shifts for several reasons: 11
l ATTACllMENT I REPLY TO NOTICE OF VIOLATION @-4 $k4 $7jj7016-07) They include: workers were not instructed that flammable / combustible liquids could not be left unattended at the tool drop-off areas unless a permit is obtained as allowed. workers were accustomed to having the RP zone technicians dispose of flammable / combustible materials during the day shift, and workers were generally unaware of the flammable storage cabinets that are e available for use in the Auxiliary Building for liquids awaiting unconditional release. The roving fire watch personnel did not know that leaving flammable / combustible liquids in the tool drop-of aread was unacceptable and therefore did not remove the flammable / combustibles from the area. The high efficiency particulate air filters that were left in the auxiliary building unattended had been staged waiting to be removed from the work area. The work group controlling these filters did not recognize that these filters contnbuted to the combustible loading in the area. CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED The identified combustible / flammable liquids were removed from the Auxiliary Building when the concern was identified. The Fire Marshalinitiated awareness tailgates for station work groups to communicate the station's standards and requirements in the fire protection area. In addition, the Fire Marshalinitiated augmented inspections of the plant to look for unattended combustibles, Initially, deviations were recognized during these inspections, however improvements were noted as the communications to the work groups on fire protection requirements were pursued. Signs have been installed at the zone technician tool drop-off areas indicating that combustible materials are not to be left at these areas and directs workers to store these materials in combustible storage cabinets. Articles were run in Braidwood's daily newsletter, *the Screaming Eagle", to increase awareness of the requirements for handling and storage of flammable liquids in the plant. The Fire Marshal reviewed requirements specified in NFPA 30 and BwAP 1100-10, " Control and Use of Flammable and Combustible Liquids and Aerosols," and concluded iaat the containers used were acceptable for use in the Auxiliary Building for the one flammable and two combustible materials specified (kerosene, mineral spirits, and denatured alcohol). 12
l KITACHMENT I REPLY TO NOTICE OF VIOLATION l s -4 %:457/97016 07) [ ACTIONS TAKEN fTO BE TAKEN) TO PREVENT RECUR *RENCE } A task force was initiated to evaluate current processes, procedures, and methods to promote personnel accountability with respect to fire protection issues. The purpose of this team is to better understand the culture that exists in work groups who must follow - fire protection procedures so appropriate changes can be made (i.e. training, j procedures, communication effods, etc.). The Fire Marshal will review the training provided to contract personnel to identify veaknesses regarding instruction of fire prevention procedures and requirements. DATE WHEN FULL COMPLIANCE WAS ACHIEVED i Full compliance war achieved when the flammable / combustible materials were removed from the identified locations to satisfy the procedure requirements. ) t k i P e h 9 i 13 9' -r w-w w vw-w s-y e-as m-r -ywr e -s wy-r-W4 ww 'w' wpup vg-* m97Dv-w,WDr -* -r'w- =--'}}