ML13323A743
| ML13323A743 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 05/01/1980 |
| From: | Papay L SOUTHERN CALIFORNIA EDISON CO. |
| To: | Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML13323A742 | List: |
| References | |
| NUDOCS 8005230227 | |
| Download: ML13323A743 (4) | |
Text
Southern California Edison Company PO. BOX 800 2244 WALNUT GROVE AVENUE ROSEMEAD, CALIFORNIA 91770 L.T. PAPAY TELEPHO$;/
VICE PRESIDENT 213 4
May 1, 1980 Mr R. H. Engelken, Director Office of Inspection and Enforcement U. S. Nuclear Regulatory Camission 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 April 11, 1980, we were requested to respond to a Notice of Violation resulting from an inspection of San Onofre Unit 1 activities which took place during the period January 28 February 29, 1980.
Our response is enclosed.
I trust the enclosure responds adequately to all aspects of the Notice of Violation. If you have any questions, or if we can provide additional information, please let me know.
Very truly yours, B.Katz/j9 cc: L. F. Miller (NRC-San Onofre Unit 1) 0III0
RESPONSE TO NOTICE OF VIOLATION DATED APRIL 11, 1980 San Onofre Nuclear Generating Station, Unit-1 10 1 Fesponse 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 the NRC inspection conducted on January 28-February 29, 1980, it appears that certain of your activities were not conducted in full copliance with the conditions of NRC License No. DPR-13 as indicated below.
A.
Technical Specification 6.9.2.b.(1) requires that reactor protection system instrument settings which are found to be less conservative than those established by the technical specifications, but which do not prevent the fulfillment of the functional requirements of affected systems, shall be the subject of written reports to the Director of the approppriate Regional Office within thirty days of occurrence of the event.
Contrary to the above requirement, at various times between October 24 and December 3, 1979, the three power range nuclear flux instruments were set from one to two percent less conservative than those established by the per tinent technical specification.
This resulted from the use of a flowmeter other than the one designated by qperating Instruction S-3-3.13, "Reactor Power Calculation."
This condition was identified on December 3, 1979, and not reported until Janaury 31, 1980.
This is a deficiency.
RESPONSE
- 1.
CORRECTIVE ACTION WHICH HAS BEEN TAKEN AND THE RESULTS ACHIEVED As discussed in our January 31, 1980 letter, the digital differential pressure meter was disconnected and the permanently installed flowmeter was utilized in accordance with Operting Instruction S-3-3.13.
- 2.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN TO AVOID FURTHER VIOLATIONS Station personnel have been further instructed regarding the requirements of station design control procedures.
- 3.
THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Station supervisory and engineering personnel were instructed in the use of design control procedure prior to the April 1980 refueling outage.
RESPONSE TO NOTICE OF
- ATION Page 2 SONGS UNIT 1 B. 10 CFR 50.55(a), Paragraph (g)(5), states, in part, that, "...components which are classified as ASME Code Class 1, Class 2 and Class 3 shall meet the requirements,....set forth in Section XI...." The applicable Addenda of Section XI (summer 1978) states that a repair may be made to the requirements of Section XI or to the requirements of the Code of Consruction.
The Code.of Construction for San Cnofre Unit 1 is ANSI 31.1.
SCE elected to use ANSI B31.1-1977.
ANSI B31.1-1977, Paragraph 106.1B states that non-standard fittings must meet the requirements of Paragraph 104.7. Paragraph 104.7 states that non-standard fittings can be used if the design is based on an analysis consistent with the general design philosophy embodied in the Code (ANSI B31.1-1977) and substantiated by proof tests and/or experimental stress analysis.
Contrary to the requirements of ANSI B31-1-1977, on February 26, 1980, a modified socket.weld fitting was used in a ASME Class 2 system, the charging pump piping, line 2019-2"-2502R, without an analysis or proof test.
This is an infraction.
RESPONSE
- 1. CORRECTIVE ACTION WHICH HAS BEEN TAKEN AND THE RESULTS ACHIEVED
-The modified socket weld fitting was replaced with a standard fitting, and the piping replacement now conforms to the requirements of ANSI B31.1-1977. This replacement was corrpleted March 14, 1980.
- 2. CORRECTIVE STEPS WHICH HAVE BEEN TAKEN TO AVOID FURTHER VIOLATIONS Further piping repairs or replacements will be performed using components which meet all requirements of the required design and constrution code.
- 3.
THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance was achieved on March 14, 1980.
C. Appendix B of 10 CFR 50, Criterion V, states in part, that, "Activities effecting quality shall be prescribed by documented instructions, proce dures,...and shall be accomplished in accordance with these instructions, procedures...."
Southern California Edison's Contractor's Work Plan Procedure No. 19.20, "Controls of Welding Filler Material," states, in part, in Paragraph 6.1.12.2, "Unused material shall be disposed of by bending...."
RESPONSE TO NOTICE OF LATION Page 3 SONGS UNIT 1 0
Contrary to the above requirements, the Resident Inspector found six rods of E308L weld filler material on the floor of the charging pump roan on February 27, 1980, that were not bent. No work was in progress in the charging pump room at the time.
The filler material was disposed of in this manner after completion of welding activities on the charging pump mini-flow line.
This is an infraction.
RESPONSE
- 1. CORRECTIVE ACTION WHICH HAS BEEN TAKEN AND THE RESULTS ACHIEVED In our response to your March 10, 1980 Notice of Violation, dated April 8, 1980, we identified corrective actions to be taken for a similiar weld rod procedure infraction. Because both infractions occured within several weeks of each other, implementation of corrective action had not been totally achieved. Corrective action has now been implemented as described in our April 8, 1980 letter.
- 2. CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS As noted in our April 8, 1980 letter, the Bechtel Work Plan/Procedure 19.20 "Control of Welding Filler Metal" will be revised to 1) standardize the quantity of weld rod used, 2) include a daily check of each Bechtel welder to assure that the total of unused rods and stubs, in the welders possession, is in agreement with the quantity issued, and 3) provides 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.
In addition to the above, station welding procedures will be reviewed and upgraded as 'appropriate.
- 3. DATE BY WHICH FULL COMPLIANCE WILL BE ACHIEVED All action relating to the Bechtel work plan have been completed.
Necessary revisions to station welding procedures will be complete by July 15, 1980.
0II