ML20206T290

Responds to NRC Re Violations Noted in Insp Repts 50-361/86-08 & 50-362/86-08.Corrective Actions:Wooden Pallets Removed Daily for Reuse,Permanent Gas Bottle Storage Rack Installed & Procedure S0123-GAD-3 Revised

ML20206T290
Person / Time
Site:	San Onofre
Issue date:	05/20/1986
From:	Ray H SOUTHERN CALIFORNIA EDISON CO.
To:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML20206T281	List: IR 05000361/1986008 ML20206T290
References
NUDOCS 8607080072
Download: ML20206T290 (8)

Text

. _ -

l

_f~DY Southem Califomia Edison Company P. O. BOX 128 SAN CLEMENTE, CALIFORNIA 92672 H ARO LO B. R AY vtCE PRESIDENT & SITE MANAGER TELEPHONE

.AN oNon E May 20, 1986 a+=7o U. S. Nuclear Regulatory Commission $,

Office of Inspection and Enforcement -

t' Region V 1450 Maria Lane, Suite 210 a Walnut Creek, California 94596-5368 7 9, - i V. '

c 4 ,-

p Attention: Mr. J. B. Martin, Regional Administrator a

Subject:

Docket Nos. 50-361 and 50-362 I. E. Inspection Reports 50-361/86-08 and 50-362/86-08 Response to Notice of Violation San Onofre Nuclear Generating Station, Units 2 and 3 1

l Mr. A. E. Chaffee's letter of April 25, 1986, issued IE Inspection 1 Reports 50-206/86-09, 50-361/86-08 and 50-362/86-08, and forwarded a Notice of Violation (NOV) resulting from the February 15 through March 27, 1986 inspection conducted by Messrs. F. R. Huey, J. P. Stewart, A. J. D'Angelo, J. E. Tatum and Ms. R. C. Tang.

The enclosure to this letter provides the Southern California Edison Company response to the Notice of Violation contained in Appendix A of Mr. Chaffee's letter of April 25, 1986. Although action has been taken in response to the conditions observed by the NRC, we respectfully request that the Notice of Violation be withdrawn. As discussed in the enclosure, we do not believe the requirements referenced as the bases for the Notice of Violation are applicable to the conditions observed, and we do not believe that the conditions warrant issuance of a Notice of Violation on any other bases.

If you have any questions, or if we can provide additional information, please let me know.

Sincerely,

Enclosure:

As stated cc: F. R. Huey (USNRC Senior Resident Inspector, Units 1, 2 and 3) 8607080072 860702 PDR ADOCK 05000361 0 PDR ~ _

fUCf

ENCLOSURE Response to the Notice of Violation contained in Appeadix A to A. E. Chaffee's letter of April 25, 1986.

Appendix A to Mr. Chaffee's letter of April 25, 1986, states:

"A. 10 CFR 50, Appendix B,_ Criterion V, states in part that, ' Activities affecting quality shall be prescribed by documented instructions, procedures,'or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. . . '

" Southern Calffornia Edison Topical Quality Assurance Manual (TQAM),

Chapter 4-C, states in part that:

1.0 Housekeeping requirements and practices shall be controlled in accordance with written procedures and instructions ...

3.0 Work activities shall be planned and implemented in a manner which assures that satisfactory housekeeping.

i practices are provided. Consideration for housekeeping should include provisions for waste removal; orderly storage of material in use;

" Administrative procedure S0123-GAO-3 (sic) titled, ' Site Housekeeping and Cleanliness Control,' defines the following requirements:

IV.A.2. Laydown and storage areas shall be kept clean and orderly; excess material shall not be allowed to accumulate.

IV.A.4. All passageways and aisles shall be kept clear.

" Fire Protection Procedure, 50123-XIII-13 titled, ' Weekly Inspection for the Control of Combustibles and Transient Fire Loads,' which implements Site Order S0123-GAO-3 (sic), states, in part, 6.2.9 All ... wood stored or used in the Protected Area shall be self-extinguishing, fire retardant or treated with fire retardant material and should be approved for intended use.

"S0123-XVI-2.0, ' Safe Practices for Storage and Handling of Compressed Gas Cylinders,'-states: l 6.1.4.1 Cylinders not securely stored in permanent areas -

shall be secured at two (2) points; the attachments  !

must be at least 1/2 inch manila rope or equivalent. I l

l 1

l

ENCLOSURE (Continued)

" Contrary to the 'above, during the period of March 10-20,.1986, the following conditions were observed on the 37 foot level-in the Units 2 and 3 Radwaste Building.

Areas adjacent to _ corridors '318 and_320 were' not kept clean and orderly, excessive materials had accumulated:in these areas and

, ' adjacent passageways were not kept clear. ' Specifically:

1

1. Approximately 100 bags of. assorted combustible materials, 8 unused wooden pallets,10 empty .

1 cardboard drums,10 empty cardboard boxes and 50 cubic feet of lumber were not in use or properly stored.

2. The access area'to corridor 318 was filled with-materials stacked 30 inches in height, and corridor 3?0 had been reduced from nine to two feet in width by improper storage of excessive materials.

3. Housekeeping control tags were not affixed-to several compressed air cylinders and wooden pallets, which were not in use.

Eight wooden pallets, which were not fire retardant or treated, were stored and not in use for a period of at 'least 10 days.

Ten compressed gas cylinders were not secured at two points,

! but only loosely supported at one point.

"This is a Severity Level IV Violation (Supplement 1) applicable to Units 2 and 3."

RESPONSE _

1. FACT AND CIRCUMSTANCES HOUSEKEEPING l

Waste and other materials, which require removal from work areas, are l

. controlled by Station Housekeeping in accordance with procedure 50123-GAD-3, " Site Housekeeping and Cleanness Control." S0123-GAD-3 states in part.(emphasis added):

"(III.8) . . . All Site supervisory personnel are responsible for l

-ensuring that the following are accomplished: 1. Work Sites under l their supervision are kept as clean and safe as is feasible for the type of work being performed . . ."

"(III.F) . . . Manager, Station Emergency Preparedness is responsible for ensuring compliance with Station housekeeping and cleanliness procedures as they relate to the-following: 1.. Adhering to the fire prevention and protection measures."

t 2

---,=-l+m- - , ,w w - ~-

ENCLOSURE (Continued)

Under this procedure, site personnel implement a " clean as you go" philosophy. Waste materials are collected, bagged or palletized, and are removed from the work area as rapidly as possible by Station Housekeeping. Periodic walkdowns of the plant are conducted by fire protection personnel to ensure identification and evaluation of housekeeping conditions to ensure fire prevention and protection measures remain effective. This program has been effective over the past year.

As noted by the inspector in the subject inspection report, he stated housekeeping was " good in most of the areas toured."

If the material is in a Health Physics (HP) control zone, in accordance with procedure 50123-VII-7.3.1, the material must be surveyed in order to prevent radioactively contaminated material from leaving the facility.

Waste found in HP control zones is moved to either the 70 foot or 37 foot elevations, where HP crews survey the material, segregating contaminated from non-contaminated waste. This program has been effective in reducing solid radwaste volume. However, the 70 foot elevation is a major access / egress passage and in November 1985, the 37 foot elevation was selected as the overflow HP survey location.

In January and February 1986, Health Physics personnel conducted refresher training classes for Project and Maintenance personnel on the

" clean as you go" responsibilities. As a result, site personnel rigorously implemented housekeeping cleanup activities, and a noticeable increase in material moved to the 37 foot elevation for HP survey occurred.

In early March 1986: Unit 3 was returning to service from an outage; Unit 2 was preparing for an upcoming outage; miscellaneous material stored in bins, cages and rooms in all levels of Units 2 and 3, which was no longer being used, was identified as needing to be removed; and, the 68 foot elevation locker room was remodeled, generating significant construction debris. These activities were recognized as producing a great influx of material into the housekeeping process, with the majority of waste being removed from inside the HP control zone.

Project and Maintenance personnel interfaced with Health Physics and Fire Protection personnel, informing them of the impending increase in the waste material generation rate. Housekeeping personnel staged the overflow material in the 37 foot elevation staging area where HP personnel surveyed it consistent'with other assigned duties. This location is not a storage area and was not being utilized for permanent or long term retention. Staging in such a manner denotes a temporary backlog situation where material accumulates, awaiting survey and subsequent release to a storage area or release for disposal.

1 3

ENCLOSURE (Continued)

In accordance with the previously quoted S0123-GAD-3, " . . . All Site supervisory personnel are responsible for ensuring that the following are accomplished: 1. Work Sites under their supervision are kept as clean and safe as is feasible for the type of work being performed . . . ", Further controls are applied to specific types of work sites in Section IV.A.2, of S0123-GAD-3 which states "Laydown and storage areas shall be kept clean and orderly; excess material shall not be allcwed to accumulate. "

Step IV.A.2 in Procedure S0123-GAD-3, addresses the interim storage of materials utilized in locations where a specific type of work activity is performed. This step was specifically developed to address concerns arising from the interim storage of materials required for construction and major maintenance activities, and is in accordance with TQAM Chapter 4-C which states in part ". . . orderly storage of material in use. . ." (emphasis added).

As cited above, this step does not address the temporary staging of materials such as the subject materials, which require surveys prior to being released from a radiological zone. Rather, general housekeeping standards that ensure "high standards of cleanliness" and " proper storage" would apply to a staging area. Although there was more material in the 37 foot elevation staging area than is SCE's normal practice, the quantities were not particularly unusual for such an area during a time when one unit was returning to service while the other unit was preparing for an outage. This material was stacked in an orderly manner and was roped or taped off, as circumstances permitted.

As previously quoted, 50123-GAD-3 states in part:

"(III.F) . . . Manager, Station Emergency Preparedness is responsible for ensuring compliance with Station housekeeping and cleanliness procedures as they relate to the following:

1. h hering to the fire prevention and protection measures . .

and " IV.A.4 All passageways and aisles shall be kept clear."

In compliance with this cited procedural step, the Manager, Station Emergency Preparedness (EP) assesses the impact of staged material on the Station's fire prevention and protection program. This is accomplished through walkdowns conducted by Emergency Services personnel (i.e. fire fighters) knowledgeable in this programmatic area.

These personnel (in consultation with a fire protection engineer) initially reviewed the location and fire loading of the 37 foot elevation as a staging area. Their review ensured that the use of this staging area would not result in an excess fire load or preclude the fire brigade from responding to a fire. The temporary impeding of access in the hallways for material staging was evaluated as acceptable by Emergency Preparedness.

In effect, although the area is architecturally a hallway, it had purposefully been redesignated as a staging area for this material. It is a suitable area for this purpose, and no other suitable area was available.

4

i ENCLOSURE (Continued)

At no time during the period when the material was being accumulated did the staging area fire rating exceed 10% of the maximum allowable combustible fire load. At no time was the fire brigade's ability to respond to a fire impaired (it should be noted that dual alternate routing always existed). Additionally, there is no safety related equipment in this area. Therefore, the staging area was a well considered, fully evaluated solution to a temporary increase in material staged, awaiting HP survey.

Material generated as a result of the Unit 3 outage was placed in the staging area, subsequently surveyed by HP, and was removed for disposal or to storage areas outside the HP control zones. During each shift, additional materials were accumulated and taken to the 37 foot elevation for HP survey. Around March 1,1986, a prior backlog of material was surveyed and all material was completely removed from the staging area.

Subsequent to the March 1, 1986 removal, an increasing backlog was indicated in EP reports datad March 4 and 10, 1986. The fire protection personnel performing the daily surveillances were not fire protection engineers. Their reports are intended to identify areas which are in turn evaluated by fire protection engineers and Health Physics personnel. As was noted in the NRC inspection report, these requests prompted Fire Protection Engineering reevaluations to ensure there were no fire brigade response impacts or quantities exceeding the combustible fire load rating (there were none).

Further, Health Physics personnel continuously tracked and assessed the material. There was no safety significance to the backlog, and HP personnel prioritized the work commensurate with its overall significance.

Between March 10 and March 20, 1986, the NRC Resident Inspector observed the activities in the staging area, and obtained Fire Safety Reports identifying the area as a concern. On March 20, 1986, the inspector contacted Fire Protection and Quality Control personnel concerning the apparent non-compliance in the staging area. On March 21 and 22, HP personnel stopped all other non-critical activities and commenced surveying and releasing the material. This activity was completed by March 26, 1986. Housekeeping personnel subsequently removed the material for disposal.

SCE acknowledges that the quantity of material on the 37 foot elevation of the radwaste building exceeded that which we would have preferred to have in the area. However, SCE concludes that: (1) no unsafe condition existed; (2) there was no safety significance to the staging of the material; (3) procedural steps in 50123-GAD-3 were not violated in the staging area. On the contrary, SCE was in compliance with the aforementioned procedure which controls housekeeping in the plant work areas, and SCE actively monitored the status of the housekeeping in the staging area.

)

l i

I I

f 5

. t.

ENCLOSURE (Continued)

WOODEN PALLETS Procedure S0123-XIII-13, Section 6.2.9, is quoted below in its entirety:

"All plastic covering sheets and wood stored or used in the Protected Area shall be self-extinguishing, fire retardant or treated.with fire retardant material and should be approved for intended use.

" NOTE: Ladders and trash receptacles are not considered transient fire loads because of their small contribution to fire loading and their regular removal."

Section 6.2.9 was written to address the use of wood that was to be placed permanently in the plant or whose use was more than transitory in nature. Our construction and maintenance efforts frequently require the use of lumber for e:. tended periods of time. As a prudent measure to ensure the lumber does not unnecessarily increase the fire hazard in the area, only treated wood is used for these activities. It is not a general industry practice to use treated wood for packaging or palletized materials as the wood becomes more brittle. It is not now, nor has it ever been, SCE's intention to apply this requirement to wooden pallets.

On the contrary, as indicated in the note to Section 6.2.9, the procedure is not applicable to certain wooden items. The wooden pallets, similar to trash receptacles, ladders and other temporary use wooden items, are of small contribution to the fire loading. Wooden pallets are regularly removed, and are in fact used to remove waste material. Therefore, the presence of wooden pallets at the staging area is expected, and the use without fire retardant is permissible.

COMPRESSED GAS CYLINDERS 4

Procedure 50123-XVI-2.0, " Safe Practices for Storage and Handling of Compressed Gas Cylinders", is an industrial safety procedure. In accordance with CAL /0SHA and the SCE Accident Prevention Manual, the procedure provides information for the safe storage and handling of compressed gas cylinders.

50123-XVI-2.0 (the current issue is Rev. O, TCN 0-3, issued January 15, 1986) contains the explicit statement that it is not QA affecting. As such, this procedure falls outside of the scope of 10 CFR 50, Appendix B, Criterion V, which controls " Activities affecting quality. . ." , with quality assurance being defined as "all those planned and systematic actions necessary to provide adequate confidence that a structure, system or component will perform satisfactorily in service." SCE considers that these non-safety related areas have been outside the scope of NRC ,

noncompliance sanctions for failure to follow procedures. In any case, '

Severity Level V would appear to apply, even if procedural compliance in  !

this area were considered subject to NRC sanctions.

l l

l l

l l

6 j 1

. . *i

• I ENCLOSURE (Continued)

SCE does maintain and fully implement a QA affecting procedure relating to the use of gas cylinders around safety related equipment:

S0123-VI-23.0, " Implementation of Site Housekeeping and Cleanness Controls". Section 6.3.17 states, " Compressed gas bottles in or about safety-related structures, systems, or components must be firmly secured or stored in a permanent structure (non-mobile racks) when not in use."

SCE acknowledges that the gas cylinders noted (which coincidently contained non-flammable gas) were not " firmly" secured. However, the staging area does not contain any safety related equipment. Furthermore, each gas cylinder had its nozzle cover in place, thereby preventing the bottle from losing its contents or becoming a missile from a stem break should the bottle fall. There was no safety significance to the subject cylinders being loosely secured.

2. CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED As previously stated, by March 26, 1986, the material was surveyed and -

removed.

As directed by Health Physics supervision, wooden pallets are now removed daily for reuse. The gas bottles were secured with two ropes by March 26, 1986, and a permanent gas bottle storage rack has been installed in the 37 foot elevation.

On May 5, 1986, procedure S0123-GAD-3 was revised to explicitly delineate different criteria for the appropriate housekeeping controls for the Health Physics survey staging areas, differentiating them from laydown and storage area housekeeping controls, provided appropriate fire protection evaluations are performed.

These corrective actions were taken as a matter of good practice and in response to concerns expressed by the NRC inspector. The conditions which existed are not considered to have violated NRC requirements.

Notwithstanding this, if procedural adherence is considered to be a generic issue in this case, unrelated to the lack of safety significance of the conditions observed, then SCE considers that Severity Level V violation would be the most severe classification warranted. Because the conditions were intentionally established for the reasons described above, this case is not considered to be a repetition of any prior violation of NRC requirements related to housekeeping.

3. CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS No further corrective actions are required.

4. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED SCE does not consider that a condition of noncompliance existed. As discussed above, actions were taken to modify the conditions noted by March 26, 1986.

8336u 7