ML20216G519
| ML20216G519 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 04/14/1998 |
| From: | Graesser K COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-454-98-05, 50-454-98-5, 50-455-98-05, 50-455-98-5, BYRON-98-0118, BYRON-98-118, NUDOCS 9804200381 | |
| Download: ML20216G519 (15) | |
Text
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Commonwealth lilnon Company ll) ton Generating $tation g
4 450 Nortti Gernun Cliurtli Road lly ron, ll. 610l D 9N 6 Tcl Hi s-23 6-s i ll April 14, 1998 LTR:
FILE:
1.10.0101 I
U.S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:
Document Control Desk
SUBJECT:
Byron Nuclear Power Station Units 1 and 2 Pesponse to Notice of Violation Inspection Report No. 50-454/98005; 50-455/98005 NRC Docket Numbers 50-454, 50-455
REFERENCE:
Geoffrey E. Grant letter to Mr. Graesser dated March 16, 1996, transmitting NRC Inspection Report 50-454/98005; 50-455/98005 Enclosed is Commonwealth Edison Company's response to the Notice of Violation (NOV) which was transmitted with the referenced letter and j
Inspection Report. The NOV cited seven (7) Severity Level IV violations requiring a written response.
Comed's response is provided in the attachment.
In the referenced Inspection Report, several examples are cited as individual violations.
In the past, violations with similar circumstances often were cited as one violation with multiple examples, We are attempting to understand the basis for this difference and would welcome an explanation. At this time, we would ask your consideraticn to group similar examples as one violation.
For example, the violations j
cited in Inspection Report No. 50-454/98005; 50-455/98005 for fire protection are called out as separate violations 05a, 05b, and 05c.
Due to commonality in reason for the violations and corrective actions, l
these three violations are grouped together in the attached response, i
This letter contains the following commitments:
1 1)
A trend investigation of OOS Program implementation issues is in progress.
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Byron Ltr. 98-0118 April'14, 1998 Page 2 2)
Station maintenance personnel will be made aware of the l
controls and requirements within station procedures (BAP 1610-9) for " Engineering Requests," through the use of department safety meetings.
l 3)
A Training Revision Request (TRR 98-113) was genera'ted to develop " Lessons Learned" training co illustrate possible effects of unevaluated additions to components.
4)
The Containment Spray Additive (CSA) Flow Verification Test (1/2BVS 6.2.2.d-1) will be revised to ensure the fire hose used to connect from Primary Water to the CSA system is free l
of foreign material prior to use.
l 5)
The Foreign Material Exclusion (FME) program will be enhanced by adding the lessons learned from the brush in the CSA system event into the NSP manuals or chapters.
6)
The Training Department will discbss the brush in the CSA system event as part of FME training as a lesson learned.
l 7)
A root cause investigation is currently in progress on 50.59 quality and failure to perform 50.59s.
8)
Placard the site where oil rag containers are located as to how many are allowed, and what material can be deposited in l
the container.
9)
Evaluate using the Waste Oil Collection Tank, for waste oil collection, and set expectations about the timeliness for depositing waste oil, 10)
Implement surveillances documenting Fire Marshall's weekly fire tour and laborers' weekly pick up of waste oil and waste oil garbage.
11)
Assess the number of oil storage lockers in the Auxiliary Building and adjust as warranted.
12)
Revise BAP 1100-9 to allow quantities of flammable liquid needed to support a job to be left at a job site while the work is in progress (i.e., through breaks, lunch, and absences to retrieve materials), during a shift or until the end of work, whichever comes first. Also, clarify that the job supervisor is responsible for ensuring that flammable / combustible materials are removed to the proper storage locations at the end of a shift or the end of work, whichever comes first.
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Byron Ltr. 98-0118 April'14, 1998 l
Page 3 13)
Provide training on revisions to BAP 1100-9 and management expectations regarding control of flammable / combustible material to applicable station / contractor personnel.
c If your staff has any questions or comments concerning this letter, please refer them to Don Brindle, Regulatory Assurance Supervisor, at (815) 234-5441 ext.2280.
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Respectfully, K. L. Gr e r
U Site Vice esident Byron Nuclear Power Station KLG/DB/rp Attachment (s) cct A. S. Beach, NRC Regional Administrator - RIII J. B. Hickman, Byron Project Manager - NRR E. W. Cobey, Senior Resident Inspector, Byron M. J. Jordan, Reactor Projects Chief - RIII F. Niziolek, Division of Engineering - IDNS (p:\\98byltrs\\980118 wpf\\3)
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ATTACHMENT I VIOLATIONS (454/455-98005-01a,b)
Technical Specification 6.8.1.g states that written procedures shall be established, implemented, and maintained for procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
a.
Appendix A of Regulatory Guide 1.33, Revision 2, February 1978, specifies equipment control, e.g.,
locking and tagging, as an example of an administrative procedure.
Byron Administrative Procedure 330-1, " Station Equipment Out-of-Service Procedure," Revision 28, Section C.6.c.4, requires, in part, that the equipment listed on the out-of-service (OOS) form be returned to service.
Out-of-Service No. 970006915 required that the Unit 1 seal water return filter 1CV02F inlet isolation valve, ICV 8396A. the Unit 1 seal water return filter ICV 02F bypass valve, 1CV8399, the control switch for the
-reactor coolant pump seal water return containment isolation valve, 1HS-CV057, and the control switch for the reactor coolant pump seal water return isolation valve, 1HS-CV082, be returned to service.
Contrary to the above, on January 17, 1998, Byron Administrative Procedure 330-1, Section C.6.c.4, was not implemented in that OoS no.
970006915 was cleared without returning to service all equipment listed on the Oos. Specifically, Unit 1 seal water return filter inlet isolation valve and bypass valve, as well as the control switches for two valves for the reactor coolant pump seal water, were not returned to service before clearing the OoS.
( 50-4 54 / 98005- 01a (DRP) ; 50-455/98005-Ola (DRP) )
This is a Severity Level IV violation (Supplement I).
b.
Regulatory Guide 1.33, " Quality Assurance Program Requirements,"
Revision 2, Appendix A, paragraph 9.e.,
states, in part, that general procedures for the centrol of maintenance, repair, replacement, and modification work should be prepared before reactor operation is begun.
Byron Administrative Procedure (BAP) 1610-9, " Engineering Requests,"
Revision 4, paragraph A, states that the procedure purpose was to explain when Engineering Requests (ERs) were used and describe the process in which ERs were submitted, completed, and administratively controlled.
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BAP 1610-9, " Engineering Requests," Revision 4, paragraph C.2.a, states l
that examples of requested activities included design changes (modifications, minor plant changes, exempt changes) and that the changes shall be processed as ER type code potential design change requests.
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Contrary to the above, on July 15, 1996, an engineering request was not proces' sed to review a potent: -
dasign change (modification) to the IB assential service water pump plior to the actual modification.
Specifically, a gasket was ir:n tlled to stop an oil leak that waa not an approved modification.
(50-4 5 s '98005-Olb (DRP) ; 50-455/98005-Olb(DRP))
This is a Severity Level IV Violation (Supplement I).
REASON FOR THE VIOLATION a.
Failure to return equipment to service as required by the OOS program We agree with the violation.
We self-identified and investigated this issue under Problem Identification Form (PIF) B1998-00313.
We determined that the failure to follow procedure, BAP 330-1, was due to a human performance error caused by the Work Execution Center (WEC)
Nuclear Station Operator (NSO) who dispatched field operators (Equipment Attendants) to clear the Out-of-Service (OOS) #970006915.
It was determined that the WEC NSO sent two field operators into the Unit 1 containment during B1ROS to clear the OOS on the inside I
containment isolation valves associated with the Local Leak Rate Test (LLRT) for the CV seal return filter penetration.
The field operators reported to the WEC NSO that the OOS was cleared and the card was contaminated and would not be returned. The WEC NSO then cleared all cards associated with this OOS, when in fact, OOS cards were still hanging on the outside containment isolation valve and in the Main Control Room, b.
Failure to submit ER prior to installing gasket in 1B SX pump We agree with the violation. On January 8, 1998, excessive axial shaft l
movement was noted on the IB Essential Service Water (SX) Pump.
I Subsequent investigation revealed that during maintenance on the 1B SX l
pump in July 1996 to repair various oil leaks from the pump lube oil I
system, a gasket was added between the main oil pump adapter and the l
outboard bearing housing. This gasket was added in a location that was the source of a chronic minor oil leak.
The addition of the gasket resulted in increasing the pump thrust bearing clearar; c by the thickness of the gasket, which brought the clearance outside the vend a recommended range.
l The gasket was added and documented in the work package for the 1B SX l
pump.
However, the gasket was added without obtaining Engineering l
assistance due to a lack of awareness, of the procedural controls and requirements in place at the time, on the part of the work crew.
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i CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED a.
Failure to return equipment to service as required by the OOS program 1.
Removed cards associated with OOS 970006915, lined up valves, and sent cards.to Central Files to attach to DOS paperwork.
2.
The Equipment Attendants were counseled concerning their communication practices.
3.
The NSO was counseled concerning his performance and to utilize human error reduction techniques.
4.
The Operating Department received OOS Program training in the 1998 first quarter requalification training session. This OOS error was shared within the Operating Department for lessons learned, DOS error performance monitoring, and 50.54 (f) reportability.
b.
Failure to submit ER prior to installing gasket in IB SM pump 1.
Vibration was checked on each SX Train pump and.notor bearing, with indications within ASME surveillance acceptance criterda.
2.
Bearing temperatures (radial) on each SX pump were checked and found normal.
3.
Operability Assessment (98-003) was completed on 1/13/98.
4.
The other three pumps were inspected and it was determined that the 2B SX pump also had a gasket installed in the same location (no gaskets on either A Train pump).
5.
Maintenance on both B Train pumps was performed to remove the gasket, inspect the thrust bearings, and restore proper thrust bearing clearance.
6.
Mechanical Maintenance Department personnel have been made aware of the controls and requirements within BAP 1610-9, through the use of department safety meetings.
l conRECTIVE STEPS THAT WILL BE TAKEN To AVOID FURTHER VIOLATION a.
Failure to return equipment to service as required by the DOS program 1.
A trend investigation of OOS Program implementation issues is in progress. This action will be tracked by NTS item #454-230 SCAQ00077.
b.
Failure to submit ER prior to installing gasket in 1B SX pump l
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1.
The remainder of station maintenance personnel will F.
lade aware of the controls and requirements within BAP 1610-9.
t.
ough the use of department safety meetings. This action la tracked by NTS item #454-100-98-00501B-01.
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2.
A Training Revision Request (TRR 98-113) was generated to develop
'" Lessons Learned" training to illustrate possible effects of unevaluated additions to components. This action is tracked by NTS item #454-100-98-00501B-02.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED a.
Failure to return equipment to service as required by the OOS program Full compliance was achieved on 1/21/98 when cards associated with OOS 970006915 were removed, valves lined up, and cards sent to Central Files to attach to OOS paperwork.
b.
Failure to submit ER prior to installing gasket in IB SX pump Full compliance was achieved on 1/30/98 (1B SX pump) and 2/27/98 (2B SX pump) when the proper thrust bearing clearance was restored.
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ATTACHMENT II l
VIOLATION (454/455-98005-02) l l
10 CFR Part 50, Appendix B, Criterion V,
" Instructions, Procedures, and l
'arewings," requires, in part, that activities affecting quality shall be l
pre scribed by documented instructions of a type appropriate to the l
cir:umstances.
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NSWP-A-03, " Foreign Material Exclusion," Revision 0, provides controls for preventing foreign material from entering systems.
Contrary to the above, on June 5, 1997, NSWP-A-03, " Foreign Material l
Exclusion," Revision 0, was not of a type appropriate to the circumstances in that it failed to prevent the intrusion of a foreign material, in the form of a condenser tube cleaning brush, into the containment spray system.
(50-4 54 /98005-02 (DRP) ; 50-4 55/98005-02 (DRP) )
This is a Severity Level IV violation (Supplement I).
REASON FOR THE VIOLATION We agree with the violation. The most probable intrusion method for the foreign material (brush) into the Containment Spray Additive (CSA) system was during CSA flow rate verification testing.
This surveillance is performed on a five-year frequency.
Pursuant to Technical Specification 4.6.2.2.d, the surveillance verifies that the sodium hydroxide solution flow-rate to the CSA Eductor is set to the required value.
In the performance of this surveillance, a fire hose is connected between Primary Water (PW) and the CSA system to provide the medium for the surveillance.
It is postulated that the fire hose used during this surveillance had been used in a drain-down of the main condenser, and, that during the drain-down, a j
condenser tube cleaning brush was caught and remained in the fire hose. This hose was then used for the connection from PW to the CSA system.
It is postulated that the brush was introduced into the CSA system during this flow rate verification test.
It is further postulated that over time, due to flow rate verification testing and the quarterly valve stroke testing, the brush migrated through the ICS01BA, and ICSO46A valves, getting caught in the ICS019A valve seat.
1 The root cause for the foreign material (brush) in the CSA system is that the Foreign Material Exclusion (FME) program was not effective at controlling entry of FM into the CSA system. Since the method of FM intrusion is j
inconclusive, why the FME program was ineffective cannot be determined.
j Although the exact method of the foreign material intrusion is not know: the most probable scenario is as described above. Assuming the most probab;s j
scenario as the intrusion method, the FME program in existence would not have been expected to prevent the intrusion.
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The date of introduction of the brushes to the site, the work history searches performed, the execution of the flow surveillance, the introduction of the fire hose replacement program and the indication of symptoms (1CS019A leak by) l all provide speculation as to the FM intrusion time frame.
The brush was not significantly deteriorated, it did however, display damage.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED 1.
The foreign material was retrieved.
l 2.
A prompt investigation was initiated, and a system recovery plan was developed.
3.
Due to leak by, 1CS020A check valve was disassembled and inspected for foreign material. The weak closure spring was replaced. No foreign material was found.
4.
The CSA system piping from the 1CS019A back to the 1CSO46A and from the i
1CS020A down to the 1CS021A was inspected using a boroscope. No foreign material was found.
5.
The ICS018A globe valve (maintained in a throttled position) was disassembled and inspected. No foreign material was found.
6.
The horizontal run of CSA piping from the 1CS018A valve back towards the ICSO40A valve was inspected using a boroscope. No foreign material was found.
7.
The CSA tank was opened and inspected for foreign material. No foreign material was found.
8.
The CS system was flushed back to the Refueling Water Storage Tank (RWST).
9.
The CSA flow rate verification test (1BVS 6.2.2.d-1) was re-performed on the Unit 1 train A CSA system.
10.
The RWST was opened following the system flush and. inspected for floating foreign material. No foreign material was found.
11.
The site FME coordinator has presented to the corporate FME WIN Team the lessons learned from this event.
12.
The FME program has been enhanced utilizing the following:
- a. Media Blitz - station newspaper, safety meetings, postings
- b. Use of mock ups displaying " proper" FME practices (p:\\98byltrs\\980118.wpf\\10)
- c. Established FME Department Representatives
- d. Developed an FME checklist covering pre-during-post activities when performing work that requires FME controls j
An article was placed in the station newspaper to further enhance foreign material awareness and the costs incurred due to this event.
14.
The Maintenance Memo (400-19) was revised to state to flush hoses prior to use.
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CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATION l
1.
The Containment Spray Additive Flow Verification Test (1/2BVS 6.2.2.d-1) will be revised to ensure the fire hose used to connect from Primary Water to the CSA system is free of foreign material prior to use.
This action will be tracked by NTS item #454-200-98-CAQS00004-01.
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The FME program will be enhanced by adding the lessons learned from this event into the NSP manuals or chapters. This action will be tracked by NTS item #454-200-98-CAQS00004-02 3)
The Training Department will discuss this event as part of FME training l-as a lesson learned.
This action will be tracked by NTS item #454-200-y 98-CAQS00004-03.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance was achieved on 2/09/98 when the inspection of the CSA system was completed with no foreign material found.
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i ATTACHMENT III I
VIOLATION (454/455-98005-04) 10 CFR Part 50.59 (a) (1) states, in part, that the holder of a license may make
' changes to the facility as described in the safety analysis report without prior Commission approval unless the proposed change involves an unreviewed safety question.
10 CFR 50. 59 (b) (1) states, in part, that the licensee shall maintain records of changes in the facility as described in the safety analysis report.
These records must include a written safety evaluation which provides the bases for the determination that the change does not involve an unreviewed safety question.
The Byron Updated Final Safety Analysis Report (UFSAR), Section 11.3.2.1,
" Gaseous Waste Management System Design," states, in part, that the gaseous waste processing system (GWPS) processes hydrogen stripped from the reactor coolant and nitrogen from the closed cover gas system. The components connected to the GWPS are limited to those which contain no air or aerated liquids in order to prevent the accumulation of oxygen in the system, i
Further, the GWPS is maintained at a pressure above atmospheric to avoid l
intrusion of air.
Hence, the GWPS will normally not contain oxygen and l
special design precautions are taken in order to avoid unintentional intrusion i
of oxygen.
Contrary to the above, on September 10, 1997, the licensee operated the GWPS j
different from that described in the UFSAR, Section 11.3.2.1, in that a system containing air was vented to the GWPS via the chemical and volume control l
system. A written safety evaluation had not been performed to determine that the change to the facility as described in the UFSAR did not involve an l
unreviewed safety question.
Specifically, Temporary Change 97-2-156 (Revision 15 dated September 10, 1997) to 2BVS 1.2.3.1-2, " Unit 2 Train B ASME Surveillance Requirements for Centrifugal Charging Pump 2B and Chemical and Volume Control System Valve Stroke Test," allowed portions of the chemical and volume control system piping that had been exposed to air during maintenance activity WR 9700068333, " Seal Injection Lines Need to be Cleaned," be vented to the volume control tank which is vented to the GWPS.
( 50-4 54 /98 00 5- 04 (DRP) ; 50-4 55/98 005-04 (DRP) )
This is a Severity Level IV violation (Supplement I),
REASON FOR THE VIOLATION We agree with the violation.
Information related to the GWPS was not identified during the search of the UFSAR for the 50.59 screening of Temporary Change 97-2-156 (Revision 15 dated September 10, 1997) to 2BVS 1.2.3.1-2,
" Unit 2 Train B ASME Surveillance Requirements for Centrifugal Charging Pump 2B and Chemical and Volume Control System Valve Stroke Test."
This search was only looking for references to the chemical and volume control system.
Although oxygen intrusion was considered by the System Engineer, it was not documented. A lack of experience and thorough knowledge and understanding of the system interactions by the engineer contributed to this event.
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CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED 1.
The realignment of the Charging Pump miniflow line was completed without incident on 9/12/97.
2.
A full Safety Evaluation (6G-98-0053) was done for the evolution of realigning an air filled Charging Pump'miniflow line to the gas space of the Volume Control Tank. The safety evaluation concluded that there was no Unreviewed Safety Question.
CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATION 1.
A root cause investigation is currently in progress on 50.59 quality and failure to perform 50.59s.
This action will be tracked by NTS item
- 454-200-98-00001.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance was achieved on 4/7/98 when Safety Evaluation 6G-98-0053 was completed.
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1 ATTACHMENT IV 1
l VIOLATIONS (454/455-98005-05a,b,c) l Technical Specification 6.8.1.g states that written procedures shall be
[
established, implemented, and maintained covering the Fire Protection Program implementation a.
Byron Administrative Procedure (BAP) 1100-9, " Control, Use, and Storage of Flammable and Combustible Liquids and Aerosols," Revision 4, Step C.6, " Cleanup of Flammable / Combustible Liquids," paragraph a, requires that' flammable or combustible liquids which are leaked or spilled shall l
be promptly cleaned up and not allowed to accumulate. Materials used to l
clean up the spill should be removed from the building.
Contrary to the above, on February 4, 1998, the licensee did not implement Procedure BAP 1100-9, paragraph C.6.a, in that the inspectors identified a large plastic trash can full of materials that had been t
l used to clean up a spill and not removed from the building.
I (50-4 54 / 98005- 05a (DRP) ; 50-4 55/ 98005- 05a (DRP) )
This is a Severity Level IV violation (Supplement I).
b.
Byron Administrative Procedure (BAP) 1100-9, " Control, Use, and Storage of Flammable and Combustible Liquids and Aerosols," Revision 4,
{
paragraph C.2.b.,
states, in part, that flammable / combustible liquid l
containers that do not require prior authorization are: 1) approved / original containers of five gallons or less being transported and used immediately in the plant while in attendance of plant i
personnel.
1 Contrary to the above, the licensee did not implement Procedure BAP l
1100-9, paragraph C.2.b., as evidenced by the following 2xamples j
(50-454/98005-05b(DRP); 50-4 55/ 98005- 05b (DRP) ) :
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e On February 4, 1998, the inspectors identified two original containers of cleaning solution, less than five gallon containers, marked as combustible, not in attendance of plant personnel at the river screen house, j
e On January 27, 1998, the inspectors identified two original l
containers of anti-seize lubricant, less than five gallon l
containers, marked as combustible, near the 1B essential service I
water pump not in attendance of plant personnel, i
e On January 30, 1998, the inspectors identified an approximately i
~
1/2-gallor. can containing oil in the Spent Fuel Pool (SFP) pump
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room not in attendance of plant personnel.
This is a Severity Level IV violation (supplement I).
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c.
Byron Administrative Procedure (BAP) 1100-9, " Control, Use, and Storage
,of Flammable and Combustible Liquids and Aerosols," Revision 4, paragraph C.2.c.,
states that aerosol containers should be transported and used in quantities not to exceed the amount needed for a specific job. These containers should not be left unattended in the plant at any time.
Storage in a Fire Marshal approved Flammable Liquids cabinet per paragraph C.5 is acceptable.
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Contrary to the above, the licensee did not implement Procedure BAP 1100-9, paragraph C.2.c., as evidenced by the following examples
( 50-4 54 /98 005-05c (DRP) ; 50-4 55/98005-05c (DRP) ) ;
On February 4, 1998, the inspectors identified three large aerosol l
cans in the river screen house unattended and not in a storage cabinet.
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On January 27, 1998, the inspectors identified two unattended cans of aerosol degreaser, not in a storage cabinet, near the 1B essential service water pump.
This is a Severity Level IV violation (Supplement I),
i REASON FOR THE VIOLATION We agree with the violations.
Each of the violations are attributable to the same reasons and the response will be directed, as one, to these reasons.
There exists a lack of clear understanding of the requirements for control of flammable / combustible materials. The procedure is vague and has allowed various interpretations by dif ferent work groups to be made.
The procedure also does not place accountability for the control / removal of material used, or generated from use, on any one person or work group.
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CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED l
1.
The oily rags and tygon hose were removed.
2.
The cleaning solution was placed in the proper storage cabinet.
3.
The cans of anti-seize lubricant were removed and placed in the proper storage cabinet.
4.
The aerosol cans of spray paint and degreaser were removed and placed in the proper storage cabinet.
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The Shift Manager was notified and the can containing oil was removed i
and returned to this proper storage cabinet.
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1 6.
The Fire Marshall met with the maintenance departments to discuss
. expectations of controlling combustibles and aerosols in the plant.
7.
The Shift Managers have informed operations personnel that flammable / combustible materials must not be left unattended in the plant and must be returned to the proper storage cabinets, or removed.
8.
A literal compliance review of our administrative procedures and j
regulations is in progress.
i 9.
Verified that oil rag containers are designated as flammable safety containers.
CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATION 1.
Placard the site where oil rag containers are located as to how many are allowed, and what material can be deposited in the container. This action will be tracked by NTS item #454-100-98-00505-01.
2.
Evaluate using the Waste Oil Collection Tank, for waste oil collection, and set expectations about the timeliness for depositing waste oil.
This action will be tracked by NTS item #454-100-98-00505-02.
3.
Implement surveillances documenting Fire Marshall's weekly fire tour and laborers' weekly pick up of waste oil and waste oil garbage.
This action will be tracked by NTS item #454-100-98-00505-03, 4.
Assess the number of oil storage lockers in the Auxiliary Building and adjust as warranted.
This action will be tracked by NTS item #454-100-98-00505-04.
5.
Revise BAP 1100-9 to allow quantities of flammable liquid needed to support a job to be left at a job site while the work is in progress (i.e.,
through breaks, lunch, and absences to retrieve materials),
during a shift or until the end of work, whichever comes first. Also, clarify that the job supervisor is responsible for ensuring that flammable / combustible materials are removed to the proper storage locations at the end of a shift or the end of work, whichever comes first. This action will be tracked by NTS Item #454-100-98-00505-05.
6.
Provide training on revisions to BAP 1100-9 and management expectations regarding control of flammable / combustible material to applicable station / contractor personnel.
This action will be tracked by NTS item
- 454-100-98-00505-06.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance was achieved on 2/04/98 when all the materials, previously identified, were properly removed and/or placed in a proper storage location.
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