ML19257D124

Responds to NRC 791129 Ltr Re Violations Noted in IE Insp Rept 50-361/79-26.Corrective Actions:Preservice Insp Procedures Revised to Require Calibr of Reactor Pressure Vessel Scanning Equipment

ML19257D124
Person / Time
Site:	San Onofre
Issue date:	01/02/1980
From:	Arenal A SOUTHERN CALIFORNIA EDISON CO.
To:	Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML19257D120	List: ML19257D124
References
NUDOCS 8002010347
Download: ML19257D124 (4)

Text

.

i Southem Califomia Edison Company P O. BO X 8 0 0

$3 2244 WALNUT GROVE AVENU E ROS EM EAD, CALIFOR N I A 91770 A.ARENAL TELEPMONE vic g e.s s.c r = v 213 572-4476 January 2, 1980

\

Mr. R. H. Engelken, Director N' >

q)

Office of Inspection and Enforcement U. S. Nuclear Regulatory Commission [f' kfQ97E9 50 _

Region V 7! J49 7 1960 ?

Suite 202, Walnut Creek Plaza i 1990 North California Boulevard 4 -'

Walnut Creek, California 94596 g. 3

Subject:

Docket Nos. 50-361 and 50-362 San Onofre Nuclear Generating Station, Units 2 and 3 In a letter from your office dated November 29, 1979, we were requested to respond te a Notice of Violation resulting from an inspection of San Onofre Units 2 and 3 construction activities which took place during the period November 3-5, 1979. 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, Enclosure cc: R. J. Pate (NRC-San Onofre Units 2 and 3) .

i855 196 ano201 0 df7 gge

t RESPONSE TO NOTICE OF VIOIATION DATED NOVEMBER 29, 1979 San Onofre Nuclear Generating Station, Units 2 and 3 Response to the Notice of Violation is provided below. A stateme.s of the condition described by the Notice is given for reference.

NOTICE OF VIOLATION

" Based upon the results of an NRC inspection conducted on November 5-9, 1979, it appears that one of your activities was not conducted in full compliance with conditions of your NRC Construction Permit No. CPPR-97 as indicated below:

Appendix B of 10CFR50, Criterion XII states, in part, that ' Measures shall be established to assure that tools ... and other measuring and testing devices...are properly controlled, calibrated...at specified periods to maintain accuracy within necessary limits.' Chapter 12 of the SCE Quality Assurance Program also requires the establishment of a system of periodic calibration to assure the accuracy of measuring and test equipment.

Contrary to the above, on November 8, 1979, ultrasonic examinations were conducted on both Unit No. 2 reactor vessel hot leg nozzles with ultrasonic search units that had not been position calibrated. A system of periodic position calibration to ensure search unit position accuracy was found to be nonexistent for the following automated exam-ination devices:

(1) Nozzle bore examination rotator.

(2) Nozz1; bore examination boom extension.

(3) Vessel to nozzle examination traversing arm.

(4) Vessel bottom head examination pivor boom.-

This is an infraction."

1855 197

e.

RESPONSE TO NOTICE OF VIOLATION Page 2

RESPONSE

1. CORRECTIVE ACTION WHICH HAS BEEN TAKEN AND THE RESULTS ACHIEVED (a) Nozzle Bore Examination Rotator.

Combustion Engineering's cognizant engineer immediately initiated Engineering Notice:; (SCE-2-EN-77 and SCE-2-EN-82) to make changes to the pre-service inspection program document No. 9976-ESS-124, Rev. O, dated 8/10/79 entitled Operation of Inservice Inspection Positioning device for the Inside Surface, Ultrasonic Examination of Reactor Pressure Vessel. The change adds the requirement for position calibration every twelve (12) hours during the performance of Nozzle examinations.

This is in addition to the existing requirements for calibrations prior to and after examinations.

Examinations conducted prior to November 8, 1979 utilizing this device were voided and the examinations were repeated utilizing the revised position check calibration procedure.

(b) Nozzle Bore Examination Boom Extcasion.

Combustion Engineering's cognizant engineer immediately initiated Engineering Notices (SCE-2-EN-7 9 arid SCE-2-EN-89) to establish requirements for Boom Extension calibrations at twenty-four (24) hour intervals during examinations and after the completion of Nozzle examinations.

Boom extend function was checked immediately upon notification of concern by the NRC Inspector ard checked again at the conclusion of the examinations.by physical measurements. Actual position, measured vs. encoder readout agreed to within + 1/16".

The remainder of the examinations were conducted between November 13-18, 1979 utilizing the revised position check calibration procedure.

(c) Vessel to Nozzle Examination Trcversing Arm.

Combustion Engineering's cognicant engineer immediately initiated Engineering Notice (SCE-2-EN-86) to establish the requirement for the repeat of the set-up calibration on the Traversing Arm every twenty-four-(24) hours when in use.

1855 198

i 1

RESPONSE TO NOTICE OF VIOLATION Page 3 This function was checked as required by Engineering Notice (SCE-2-EN-86) throughout the remaining examinations (November 9 through November 18). This function measurement met the requirements of + .5" as instituted by Combustion Engineering's calibration check procedure.

(d) Vessel Bottom Head Examination Pivot Boom.

Combustion Engineering's cognizant engineer immediately initiated Engineering Notice (SCE-2-EN-79) to establish the requirement for calibration of the Boom Extension at the completion of all examinations requiring the Pivot Boom.

The pivot boom was checked prior to its use and immediately after examinations were concluded. These checks were made at both the 0 and 90 orientation of the boom. The results of this measurement showed a deviation of .5 which is within the tolerances required by Combustion Engineering's calibration check procedure.

2. CORRECTIVE STEPS WHICII WILL BE TAKEN TO AVOID FURTIIER VICLATIONS The pre-service inspection program procedures have been revised to require calibration of the RPV scanning equipment prior to, during, and after examinations to confirm position calibration.

3. DATE BY WIIICII FULL COMPLIANCE WILL BE ACHIEVED Full compliance was achieved on November 18, 1979, when the pre-service inspection program procedures were revised to include periodic calibration of the RPV scanning equip-ment and calibration checks on the scanning equipment were determined to be within required tolerances.

1855 199