ML13323A705
| ML13323A705 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 04/08/1980 |
| From: | Papay L SOUTHERN CALIFORNIA EDISON CO. |
| To: | Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML13323A703 | List: |
| References | |
| NUDOCS 8005220214 | |
| Download: ML13323A705 (4) | |
Text
Southern California Edison Company P. 0. BOX 800 2244 WALNUT GROVE AVENUE L. T. PAPAY ROSEMEAD, CALIFORNA 91770 VICE PRESIDENT April 8, 1980 213-572-1474 Mr. R. H. Engelken, Director Office of Inspection and Enforcement U. S. Nuclear Regulatory Commission Region V Suite 202, Walnut Creek Plaza 1990 North California Boulevard
-Walnut Creek, California 94596
Dear Mr. Engelken:
Subject:
Docket No. 50-206 San Onofre Nuclear Generating Station, Unit 1 In a letter from your office dated March 10, 1980, we were requested to respond to a Notice of Violation re sulting from an inspection of San Onofre Unit 1 modification activities which took place during the period January 29 February 1 and February 6-7, 1980. Our response is enclosed.
I trust the enclosure responds adequately to all aspects of the Notice of Violation. If you have any ques tions, or if we can provide additional information, please let me know.
Very truly yours, Enclosure cc:
L. F. Miller (NRC-San Onofre Unit 1)
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RESPONSE TO NOTICE OF VIOLATION DATED MARCH 10, 1980 San Onofre Nuclear Generating Station, Unit 1 Response to the Notice of Violation is provided below. A statement of the condition described by the Notice is given for reference.
NOTICE OF VIOLATION Based on the results of an NRC inspection on January 29 February 1, 1980, it appears that one of your activities was not conducted in full compliance with conditions of your NRC Facility License No. DPR-13 as indicated below:
10CFR Part 50, Appendix B, Criterion V states, in part, that "Activities affecting quality shall be....
accomplished in accordance with....procedures...".
The San Onofre Unit #1 Quality Assurance Manual, Chapter 5, Paragraph 5.1 states, in part, that "Activities related to...construction and testing of the ECP shall be controlled by approved instructions, procedures, and drawings."
Bechtel Procedure WPP 19.20 for control of weld filler material contains the following requirements:
(1) Paragraph 4.4 - all welding filler material to be discarded shall be destroyed by bending prior to discarding.
(2) Paragraph 4.6 - Individual welders shall keep their work areas clear of unauthorized or dis
.carded weld filler material. Electrode stubs and damaged filler materials shall be placed in stub buckets. At the end of the work shift, the unused filler material shall be returned to the rod room for reissue or disposition by the rod personnel.
(3) Paragraph 6.1.1 - No welding filler material will be issued without a properly executed rod request form.
RESPONSE TO NOTICE OF VIOLATION -
SONGS 1 Page 2 (4) Paragraph 6.1.6 -
At the completion of the welder work shift, the portablefrod warmer, pouch, all unused filler material and the welder's copy of the WR-6 or WR-99 form shall be.returned to the rod room attendant.
Contrary to the above, on January 30, 1980, in the area of the auxiliary feedwater system piping modifications the inspector identified the following conditions prior to commencement of that days welding activities:
(1) Two E-70S and Two E7018 weld rod stubs on the floor.
(2) Four full length E-7018 low hydrogen rods that had not been bent and twenty E-7018 weld rod stubs in a cardboard box on the floor.
(3) Eighteen E-6011, five E-70-S2 and four coated nickel weld rods in a Bechtel welder's tool box. A weld rod issue form was not available.
This is an infraction.
RESPONSE
- 1. CORRECTIVE ACTION WHICH HAS BEEN TAKEN AND THE RESULTS ACHIEVED All weld rod stubs were properly discarded and all weld rod was destroyed.
Weld rod found in the Bechtel welder's tool box was destroyed. As this weld rod was not issued from the SO-1 jobsite rod room for this particular job (auxiliary feedwater system piping modification) there were no weld rod issue papers. A check was subsequently made of all Bechtel tool boxes on the job and any weld rod which was found was removed and destroyed.
All Bechtel superintendents were required to read the Work Plan/Procedures applicable to weld rod control and to verify that the Bechtel crafts fully understood the requirements of the procedures.
RESPONSE TO NOTICE OF VIOLATION -
SONGS 1 Page 3
- 2. CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS Additional Bechtel Engineering, and Craft personnel, will be assigned to the Project during the upcoming April, 1980 refueling outage to help in assuring that Bechtel procedural requirements are implemented.
A more formal approach to training of project personnel will be implemented by Bechtel prior to the April, 1980 refueling outage.
Full time Bechtel Quality Assurance personnel will be assigned to the Project during the April, 1980 outage and will perform surveillance to assure conformance to Bechtel procedures.
Bechtel Work Plan/Procedure 19.20 "Control of Welding Filler Metal" will be revised to:
(1) Standardize the quantity of weld rod issued.
(2) Include a daily check of each Bechtel welder to assure that the total of unused rods and stubs, in the welder's possession, is in agreement with the quantity issued.
(3) Provide for a check, at the end of each shift or welding operation, to assure that all weld rod stubs have been removed from the job.
- 3. DATE BY WHICH FULL COMPLIANCE WILL BE ACHIEVED All remedial actions, delineated in Item 1 above, were completed on February 1, 1980. With the exception of the revision to the Bechtel Work Plan/Procedure 19.20, all corrective actions detailed in Item 2 above, will be completed by April 7, 1980. Procedure 19.20 will be revised by April 11, 1980.