IR 05000729/2009026
| ML13323B035 | |
| Person / Time | |
|---|---|
| Site: | San Onofre, 05000729  |
| Issue date: | 10/17/1985 |
| From: | Johnson P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML13323B032 | List: |
| References | |
| 50-362-85-26, NUDOCS 8511040161 | |
| Download: ML13323B035 (3) | |
Text
APPENDIX A NOTICE OF VIOLATION Southern California Edison Company Docket Nos. 50-362 San Onofre Unit 3 License Nos. NPF-15 As a result of the inspection conducted during the period July 29 through September 26, 1985, certain violations of NRC requirements were identifie In accordance with the General Statement of Policy and Procedure for NRC Enforcement Actions, 10 CFR Part 2 Appendix C, as revised, 49 FR 8583 (March 8, 1984), the violations are set forth below: CFR 50.59 states, in part, that:
"(a)
(1) The holder of a license authorizing operation of a production or utilization facility may (i) make changes in the facility as described in the safety analysis report...without prior Commission approval, unless the proposed change, test or experiment involves a change in the technical specifications incorporated in the license or an unreviewed safety questio (2) A proposed change, test, or experiment shall be deemed to involve an unreviewed safety question (i) if the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report may be increased...."
"(b) The licensee shall maintain records of changes in the facility....These records shall include a written safety evaluation which provides the bases for the determination that the change, test or experiment does not involve an unreviewed safety question."
Procedure number AP-13, titled, "Administrative Procedure Construction Safety Evaluation" provides direction to the responsible work or test organization in the preparation and submittal of a CSE (Construction Safety Evaluation) and states in part that:
"As specified in 10 CFR 50.59 a 'written safety evaluation' shall be prepared that provides the determination that the change, test or experiment does not involve an unreviewed safety hazard by virtue of possible damage to nearby existing permanent plant equipment".
Paragraph 8.3.1.4.1.1 of the FSAR states in part:
"Cables associated with each separation group...are run in separate conduits, cable trays, ducts, and containment penetrations."
Paragraph 8.3.3.3.1 of the FSAR provides criteria for minimum separation distances of 1 foot horizontal and 3 feet vertical to be maintained between different separation groups (four Class IE groups and one non-class IE group).
8511040161 851017 PDR ADOCK 05000206 RPDR
Contrary to the above, on August 18, 1985, the following conditions were found to exist: Switchgear room 302B contained scaffolding erected and supported from overhead cable tray support The CSE which was provided for temporary installation of scaffolding did. not document the bases for concluding that the additional load of the scaffolding on the safety-related cable tray supports did not involve an unreviewed safety questio.
The Construction Safety Evaluation (CSE) for Design Change-Package (DCP) 3-6160.0J stated in part:
"Temporary power feeder cable, or any other cable capable of being energized... shall be suspended below, with a minimum 3" separation, from any Class II cable tray, conduit, or other nuclear safety related equipment where possible."
This CSE did not require the use of conduit and specified a 3" separation criterion which was less conservative than the criteria established by the FSAR. The CSE did not document the bases for concluding that these less conservative criteria did not involve an unreviewed safety questio This is a Severity Level IV Violation (Supplement I) applicable to Unit CFR 50 App. B Criterion V states in part:
"Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings...and shall be accomplished in accordance with these instructions, procedures, or drawings."
The CSE for DCP 3-6160.OJ states in part:
"Temporary power feeder cable, or any other cable capable of being energized (excluding communication or other low energy cabling)
shall be suspended below, with a minimum of 3" separation, from any Class II cable tray,.conduit, or other nuclear safety related equipment where possible. If it is not possible to suspend the temporary cable below the safety related equipment, then adequate measures shall be taken to prevent the dropping or sagging of the cable onto the safety related equipment. During installation or removal of temporary cabling, it shall not be allowed to sag or drag across any safety related equipment."
Contrary to the above requirements, on August 18, 1985, inspectors identified several instances of welding cable and temporary power cable being routed across and in direct contact with Class IE (Quality Class II) cable trays in Unit 3 cable spreading and swtichgear room This is a Severity Level IV Violation (Supplement I) applicable to Unit Pursuant to the provisions of 10 CFR 2.201, Southern California Edison Company is hereby required to submit to this office within 25 days of the date of this Notice, a written statement or explanation in response to each of the above violations, including: (1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further violations, (3) the date when full compliance will be achieve Consideration may be given to extending your response time for good cause show ICT 17 8985 Dated./Johnson, Chief Rea cr Projects Section 3 0II