ML13331A139
| ML13331A139 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 08/03/1981 |
| From: | Papay L SOUTHERN CALIFORNIA EDISON CO. |
| To: | Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML13331A140 | List: |
| References | |
| NUDOCS 8109090343 | |
| Download: ML13331A139 (11) | |
Text
Southern California Edison Company P. 0. BOX 800 2244 WALNUT GROVE AVENUE ROSEMEAD, CALIFORNIA 91770 TELEPHONE L.T. PAPAY 213-572-1474 VICE PRESIDENT August 3, 1981 U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region V 1990 North California Boulevard Suite 202, Walnut Creek Plaza Walnut Creek, California 94596 Attention: Mr. R. H. Engelken, Director DOCKET No. 50-206 SAN ONOFRE -
UNIT 1
Dear Sir:
Your letter of July 9, 1981, forwarded a Notice of Violation resulting from IE Inspection Report 50-206/81-22 which took place June 2 through June 5, 1981. to this letter provides our response to your Notice of Violation. to this letter provides our response to your concerns regarding our apparent failure to comply with IEEE 384 separation criteria during the recent installation of safety-related electrical cables within, and within the near vicinity of, existing (old) control panels.
U. S. Nuclear Regulatory Commission
-2 I trust the enclosures respond adequately to all aspects of the Notice of Violation and to your concerns regarding compliance with IEEE 384 separation criteria. If you have any questions or if we can provide additional information, please let me know.
Subscribed on the
_31L_1 day of August, 1981.
Vice President Southern California Edison Company Subscribed and sworn to before me this3/aday of August, 1981.
OWMAL SEAL AGNES CRABTREE
- j NOTARY RJBUC - CALIFORNIA PRINCIPAL OFFICE IN LOS ANGELES COUNTY MyCommissionEyp.Aug.27,1982_ Notar Public in and for the County W
=of L s Angeles, State of California JDDunn:cs Enclosure cc: L. F. Miller (NRC Site Inspector -
San Onofre Unit 1)
Response to items of Noncompliance identified in Appendix A to IE Inspection Report No. 50-206/81-22 ITEM A.
10CFR 50 Appendix B, Criterion IX, states in part:
"Measures shall be established to assure that special processes, including...nondestructive testing, are controlled and accomplished by qualified personnel using qualified procedures in accordance with applicable codes...."
Design Change 80 Safety and Environmental Analysis for Addition of Mechanical Penetrations for Sampling, third paragraph, states in part:
The systems and equipment included in this design change will be designed, manufactured and installed as safety-related quality class.
Section III of the ASME Boiler and Pressure Vessel Code will be applied...."
Applicable Design Drawing No. 235398 -
Sphere Penetration Sample Line Cap No.
B16A & B states, in part:
"Field weld...per ASME...Section III, subsection NE, Cat. B.
radiograph required."
ASME B&PV Code,Section III, subsection NE, requirement NE-5111 states, in part:
"...Radiographic examination shall be in accordance with Section V, Article 2..."
ASME B&PV Code,Section V, Article 2, requirement T-263(a),
states in part:
"...If the density of the radiograph anywhere through the area of interest varies by more than minus 15% or plus 30% from the density through the body of the penetrameter...then an additional penetrameter shall be used for each exceptional area or areas and the radiograph retaken."
ASME B&PV Code,Section V, Article 2, requirement T-263.1(c),
states in part:
"Where inaccessibility prevents hand placing the penetrameter on the source side... the penetrameter shall be placed on the film side of the part and a lead letter"F" at least as high as the identification number shall be placed adjacent to the penetrameter."
ASME B&PV Code,Section V, Article 2, requirement T-221.2 states in part:
"...weld ripples shall be removed to such a degree that the resulting radiographic image cannot mask or be confused with the image of any discontinuity."
-2 Contrary to the above, it was noted on June 2, 1981, that:
(1) the radiographs taken for mechanical penetrations B16A and B did not contain an adequate number of penetrameters to assure sufficient radiographic sensitivity through the area of
- interest, (2) the radiographs did not show the lead letter "F" on the film even though the penetrameters had been placed on film side of the parts, and (3) the radiographs showed weld ripples that could mask discontinuities that may be present in the welds.
This is a Severity Level V Violation (Supplement II)
RESPONSE
- 1.
Corrective Steps Which Have Been Taken and Results Achieved The above violation has been thoroughly discussed with the Contractor, Mobile Inspection Services, Inc.
(MISI).
MISI has concluded that items (1) and (2) occurred as a result of an oversight and misinterpretation of the Code requirements and has assumed full responsibility for the occurrances accordingly.
As a result the following corrective steps were taken:
- a.
Because the geometrical configuration of the sphere mechanical penetrations B16A and B prohibits utilizing normal exposure parameters, a more detailed radiographic procedure MISI-RT-2, requiring twenty exposures and penetrameters, and also detailing the placement of the lead letter "F" on the circumference, was prepared by MISI.
- b.
MISI submitted the procedure, MISI-RT-2, to Edison and the procedure was reviewed and approved by the Edison ASNT Level III Examiner and the resident Authorized Nuclear Inservice Inspector (Kemper Insurance) on June 12, 1981.
- c.
The mechanical penetrations B16A and B were re radiographed, to the new procedure MISI-RT-2, on June 12, 1981.
The resulting radiographs were interpreted and accepted by the MISI Level III Examiner, Edison Quality Assurance Level III Examiner and the resident Authorized Nuclear Inservice Inspector.
It was concluded that the re-radiographs conformed to the requirements of the ASME B&PV Code Section V, Article 2, requirement T-263(a) and T-263.1 (c).
- d.
With respect to item (3) of the above violation it is considered that the possibility of weld ripple tariig is subject to radiographic film interpretation by a qualified NDE Level II or Level III Examiner.
As interpreted by the contractor's qualified Level III Examiner, and based on film density measurements of the ripple area, it was his determination that the weld ripples as shown on the re-radiographs were minimal and the film densi.ty of the ripple area was not sufficiently dark as to obviate an out of specification discontinuity.
- 2.
Corrective Steps Which Will be Taken to Avoid Further Items of Noncompliance In the future, the Edison Quality Assurance Level III NDE Examiner will review and approve all radiographs and associated documentation prepared by outside contractors to assure that compliance with applicable codes, standards, specifications and special procedures has been met. This review and approval will be documented.
Appropriate quality assurance procedures will be revised to require the performance and documentation of this review.
- 3.
Date When Full Compliance Will Be Achieved
- a.
Full compliance with items (1),
(2) and (3) was achieved on June 12, 1981.
- b.
The revision of appropriate quality assurance procedures will be complete by August 31, 1981.
Item B. 10CFR50, Appendix B, Criterion V, Instructions, Procedures, and Drawings states:
"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.
Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished."
- 1. Southern California Edison Document AD12-A, Project General Design Criteria Manual, defines governing design criteria applicable to changes to the San Onofre Nuclear Generating Station, Unit 1 plant, to be accomplished under the Three Mile Island recommendation implementation project. This Design Criteria Manual states in Section 3.1.A:
"Where the existing systems and equipment interface with newly designed systems and equipment, previously established criteria (FSAR and amendments) for San Onofre Unit 1 shall apply throughout the existing systems including the interface point.
Beyond the interface point, for new systems and equipment, the criteria established in this design criteria manual shall apply."
The Design Criteria Manual further states in paragraph 3.7:
"To ensure that the total installed safety-related system shall satisfy the single-failure criteria, as stated in IEEE Standards No. 279 and 379, provisions.
shall be made for isolation or separation of the electric equipment and circuits of one redundant system from those of other redundat systems in accordance with the requirements of NRC Regulatory Guide 1.75 unless otherwise specified."
Regulatory Guide 1.75 adopts IEEE Standard 384.
The Design Criteria Manual also states in paragraph 4.2 "The control systems, equipment and components shall comply with the applicable criteria, codes and standards (of) IEEE 384-1977 standard criteria for independence of Class 1E equipment and circuits."
IEEE 384 requires that "Where the control switchboard materials are flame retardant...the minimum separation distance shall be 6 inches (15.24 cm)."
Contrary to the above, on June 3, 1981, and June 4, 1981, it was found that the required 6-inch separation was not maintained betweeen Class 1E and Non-Class 1E circuits internal to new auxiliary feedwater instrumentation panels C-69 and C-70. A review of quality control inspection records disclosed that the requirements for separation and independence for safety-related electrical circuits installed under the Three Mile Island recommendation implementation project were not included in quality control inspection criteria and cable routings to meet these requirements were not specified on installation drawings.
This is a Severity Level V Violation (Supplement II).
RESPONSE
- 1.
Corrective Steps Which Have Been Taken and Results Achieved An investigation into the situation confirmed that separation criteria for maintaining adequate clearance between Class 1E and Non-Class 1E circuits was not met in new Foxboro Panels C69 and C70 which were installed for the TMI modifications. The cause of this problem was the result of a failure to follow established procedures for verifying original design or design changes with the design input requirements which are stated in the Design Criteria Manual. As a result the following corrective steps were taken:
-5
- a.
A Nonconformance Report (NCR 1650) was issued against the affected Panels C69 and C70 on June 9, 1981.
- b.
Drawing Configuration Change Notices were issued to install a suitable metal barrier on panels C69 and C70 to provide the necessary separation.
- c.
Installation of metal barriers at the appropriate locations on panels C69 and C70 were completed prior to June 11, 1981.
- d.
The disposition of NCR 1650 was verified by Edison Quality Assurance on June 11,1981.
This verification disclosed that the required separation between Class IE and Non-Class IE cables was satisfactorily accomplished by the installation of barriers on Panels C69 and C70.
- 2.
Corrective Steps Which Will Be Taken to Avoid Further Items of Noncompliance Procedures currently in effect concerning the preparation, review and approval of design drawings and revisions will be adhered to without exception.
Responsible supervision will continue to reinforce and emphasize to engineering design personnel the necessity to use existing design disclosure document review and design input requirements.
- 3.
Date When Full Compliance Will Be Achieved With the exception of the above-reported violation, the Edison Engineering Design Organization was and remains in full compliance with the procedural requirements for preparing, issuing, and approving design disclosure documents. However, Edison Quality Assurance will conduct a training session for all appropriate Engineering Supervision personnel to further emphasize the necessity for adhering to design disclosure documents throughout all phases of design construction, installation and testing. This training will be completed prior to August 31, 1981.
- 2.
Bechtel Work Plan Procedure/Quality Control Instruction Number 20.12 specifies that, for safety-related concrete expansion anchors, the applicable discipline quality control engineer shall participate in visual inspection, torque testing, and documentation of anchor installation.
-6 Contrary to these requirements, it was noted on June 4, 1981, that concrete expansion anchors providing seismic support for safety-related auxiliary feedwater automatic initiation instrument panel C-69 did not have fully engaged and torqued nuts.
Additionally, a review of quality control inspection records disclosed that these nuts had been installed without the required quality control inspections and documentation.
This is a Severity Level V Violation (Supplement II).
RESPONSE
- 1.
Corrective Steps Which Have Been Taken and Results Achieved The condition described by the above violation was subsequently identified on a Nonconformance Report and was investigated by Bechtel Quality Control personnel.
The loose Hilti Anchor Bolts were torqued and inspected and found to be within acceptable limits.
In addition, generalized inspections were performed in other work areas to verify that no other conditions similar to that identified existed. The areas inspected were:
Control Room Dog House 4160 Volt Room DC Battery Room 480 Volt Room Containment Nitrogen Line Auxiliary Feedwater System Reactor Head Vent Line No deficiencies were found.
- 2.
Corrective Steps Which Will Be Taken To Avoid Further Items of Noncompliance (a) Bechtel Quality Control Instruction 20.14 to be written and issued by July 31, 1981 will require Quality Control to perform a general inspection of surrounding areas when doing final inspection for a given work package. The inspection activities will be documented on Field Inspector's Reports.
(b) A training session for cognizant Quality Control personnel in the requirements of Quality Control Instruction 20.14 will be conducted and documented upon its release.
The training session is scheduled to be completed by August 14, 1981.
- 3.
Date When Full Compliance Will Be Achieved Full compliance will be achieved by August 14, 1981.
JDDunn:cs 0265 Item:
Concerns Identified in NRC Forwarding Letter Dated July 9, 1981, IE INSPECTION REPORT 50-206/81-22.
As we explained in our telephone discussion with Mr. J. M. Curran on June 12, 1981, the NRC has concerns regarding your apparent failure to comply with IEEE 384 separation criteria during the recent installation of safety-related electrical cables within, and within the near vicinity of, existing (old) control panels.
Therefore, please include in your reply to the Notice of Violation (1) your basis or justification for not applying the IEEE 384 separation criteria for newly installed cables in and near existing control panels, especially since NUREG 0737, Appendix B, implies that such separation should be attained, and (2) your analysis which shows that the new cables, as installed, have not degraded the operational safety of existing cables, instrumentation and control systems, and (3) any plans you have to revise or modify the installation of this recently installed cabling to comply with IEEE 384 separation criteria."
RESPONSE
- a.
Basis and Justification
References:
- 1.
Design Criteria Manual, Three Mile Island Project October 1979.
- 2.
Letter, J. B. Moore, SCE, to E. G. Case, NRC Amendment 38 Docket 50-26, Provisional Operating License No.
The criteria used for TMI modifications are stated in Reference 1 and read in part:
"3.1 GENERAL A.
Where the existing systems and equipment interface with newly designed systems and equipment, previously established criteria (FSA and amendments) for San Onofre Unit 1 shall apply throughout the existing systems including the interface point. Beyond the interface point, for new systems and equipment, the criteria established in this Design Criteria Manual shall apply;"
2 and "3.7 PHYSICAL INDEPENDENCE OF ELECTRICAL SYSTEMS Where systems and equipment are provided for safe shutdown, redundant systems shall be provided in accordance with IEEE 308 and NRC Regulatory Guides 1.6 and 1.32 so that failure of a system component will not result in failure to shutdown safely.
To ensure that the total installed safety-related system shall satisfy the single-failure criteria, as stated in IEEE Standards No. 279 and 379, provisions shall be made for
- isolation or separation of the electric equipment and circuits of one redundant system from those of other redundant systems in accordance with the requirements of NRC Regulatory Guide 1.75 unless otherwise specified."
For the TMI modifications, the "existing" equipment involved are the main control room panels. Some of these panels are open, having no backs or tops and others are fully enclosed. The panels were originally designed and constructed prior to implementation of IEEE-384.
Therefore, IEEE-384 standards were not used in the original design of the panels.
The interface point mentioned in paragraph 3.1.A is the point of termination of the raceway. This point was first chosen during the Standby Power Addition retrofit project (1976-77) and has been the interface between "old" and "new" for all subsequent retrofit projects.
Reference 2 describes the Standby Power Addition retrofit project and the design standards and criteria used and reads, in part:
"4.1 GENERAL All plant changes associated with the standby power addition and ECCS modifications which involve new structures, systems and equipment are made in accordance with present-day design requirements as far as practicable."
This philosophy has been used for all subsequent retrofit projects.
For enclosed panels, the interface point is where the raceway terminates at the cabinet.
For cabinets which have no backs or tops, the raceway terminates as near as practicable to the existing control panel. The inter face point is then, logically, the end of the raceway and is consistent with the criteria stated in Reference 2.
3 The results of this evaluation are that the modifications were made in compliance with the stated criteria and that there were no deviations from the existing design basis.
- b.
Analysis of Degradation of Operational Safety of Existing Cables, Instrumentation Control System The installation of Class 1E circuits in existing panels has been limited to low energy and instrumentation and control cables in an area of high visibility, namely, the control room. During the life of the plant no event has occurred which can be attributed to the interfacing that involves routing of new Class 1E circuits in existing panels.
- c.
Plans to revise or modify the installation of recently installed cabling to comply with IEEE 384 criteria The recent installation is consistent with the design basis and project design criteria for the TMI modifications.
The original design basis and the use of the above criteria for performing modifications will be reviewed as part of the Systematic Evaluation Program.
0261Q