ML19322E645
| ML19322E645 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 03/04/1980 |
| From: | Papay L SOUTHERN CALIFORNIA EDISON CO. |
| To: | Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML19322E642 | List: |
| References | |
| NUDOCS 8004020049 | |
| Download: ML19322E645 (5) | |
Text
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Southern California Edison Company
$3 A O. BOX 800 2244 WALNUT GROVE AVENUE ROSEMEAD, CALIFORNIA 91770
,p watt pers ocer g 3 572 e474 March 4, 1980 Mr. R. H. Engelken, Director d')
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U. S. Nuclear Regulatory Commission W
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Suite 202, Walnut Creek Plaza
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1990 North California Boulevard Walnut Creek, California 94596
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Dear Mr. Engelken:
Subject:
Docket Nos. 50-361 and 50-362 San Onofre Nuclear Generating Station, Units 2 and 3 In a letter from your office dated February 4, 1980, we were requested to respond to a Notice of Violation resulting from inspections of San Onofre Units 2 and 3 construction activ-ities which took place during the periods November 13-16, and December 11-14, 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, YY Enclosure cc:
R. J. Pate (NRC-San Onofre Units 2 and 3) 8 00 4020 0+1 g,- / 7
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RESPONSE TO NOTICE OF VIOLATION DATED FEBRUARY 4, 1980 San Onofre Nuclear Generating Station, Units 2 and 3 Response to the Notice of Violation is provided herein.
A statement of each condition described by the Notice is given for reference, followed by the specific response.
" Based on the results of NRC inspections conducted en November 13-16 and December 11-14, 1979, it appears that three of your activities were not conducted in full compliance with the conditions of your NRC Construction Permit No. CPPR-97/98 as indicated below:
10CFR50, Appendix B, Criterion V requires that ' activities affecting quality shall be... accomplished in accordance with... instructions, procedures, and drawings.'
Bechtel Power Corporation procedure WPP/QCI 008, Revision 10, a.
states in paragraph 4.5.6.1 that ' items in storage shall have all covers, caps, plugs, and othe' closures intact.'
Contrary to the above requirements on November 15, 1979, four uncapped inlet sensing lines were identified during an inspec-tion of eight pressure transmitters at Unit 2.
These transmitters were associated with the reactor protective system, high pres-surizer trip and low pressurizer pressure trip functions.
This is a deficiency."
RESPONSE
1.
Corrective Steps which Have Been Taken and the Results Achieved The open ports / tubing for instruments 2PT-0101-1, 2PT-0101-2, 2PT-0101-03, and 2PT-0102-2 were immediately capped with the appropriate Cover.
A review of the conditions to which the Pressure Transmitters had been subjected established that no damage or harmful effect took place during the time the sensing lines were without covers.
Bechtel Quality Assurance performed surveillance in Units 2 and 3 and ascertained that the condition noted was an isolated occurrence.
RESPONSE TO NOTICE OF VIOLATION DATED FEBRUARY 4, 1980 Page Two SAN ONOFRE UNITS 2&3 2.
Corrective Steps which will be Taken to Avoid Further Violations Bechtel Instrumentation Craft supervision have been instructed to be constantly alert to cleanliness requirements as established by Bechtel work procedures.
Bechtel Quality Control and Field Engineering will continue to perform inspection / monitoring of Housekeeping requirements per WPP/QCI-009.
3.
Date by which Full Compliance will be Achieved Full compliance was achieved on November 19, 1979, when protective caps were installed and appropriate instructions were given to craft supervision.
"Bechtel Power Corporation Construction specification CS-301
' Installation of Electrical Cables in Conduit and Duct Banks,'
specifies in Table 9.3 a 1.5 inch minimum bend radius for 3 conductor 14 AWG cable.
The inspector noted a 3 conductor (3/c) 14 AWG, Class IE cabic, which had been doubled back on itself (2-180 bends) and stuffed into a 2-1/2 inch conduit (1 CAT 09) in order to take up excess cable length.
This cable was connected to the 125 volt distribu-tion switchboard 201 in battery charging room 310A.
This is an infraction."
RESPONSE
1.
Corrective Steps which Have Been Taken and Results Achieved A Nonconformance Report (NCR E-1160) was baitiated against cable scheme No. 2AD1ROA, addressing this violation of the minimum bend radius for a 3 conductor 14AWG cable, as defined in CS-E01.
This NCR has been dispositioned " Rework," which will be accomplished by replacing the subject cable scheme with a new cable.
An in-depth surveillance has been conducted by Bechtel Quality Assurance and it has been ascertained that the subject viola-tion of the minimum bend radius is an isolated occurrence.
RESPONSE TO NOTICE OF VIOLATION DATED FEBRUARY 4, 1980 Page Three SAN ONOFRE UNITS 2&3 2.
Corrective Steps which Will be Taken to Avoid Further Violations Current procedural controls for the monitoring of minimum bend radius will be emphasized.
WPP/QCI-604 provides that Bechtel Quality Control shall inspect cabic 'ulling activities of each cable pulling crew four (4) times per shift, as a minimum.
Cables are checked throughout the run, including inside conduit fittings if used, to ensure that minimum bend radius is not exceeded for any cable in the run.
3.
Date by Which Full Compliance Will be Achieved Full compliance will be achieved by March 14, 1980, when the replacement of cable scheme No. 2AD1ROA will be complete.
"Bechtel Quality Control Instruction 100.0 Weld Filler Material Control:
specifies ' at the completion of the work shift, the...
unused filler material... shall be returned to the rod room...'
Contrary to the above requirements, on November 15, 1979, the inspector found twelve unused E7018 weld electrodes lying in the outlet nozzle of the. Unit 3 refueling water storage tank.
No welding was being performed in the area at the time of the find-ing.
Also, the electrodes appeared to have been uncontrolled for some time as evidenced by corrosion on the tips of the rad.
This is an infraction."
RESPONSE
1.
Corrective Steps which Have Been Taken and the Results Achieved An investigation was conducted and determined that the subject rod originated from Brown-Minneapolis Tank (BMT), an on-site contractor for tank erection.
This was determined by tracing the electrode lot identification code numbers to records maintained by BMT.
Both Bechtel and BMT Quality Assurance personnel performed surveillances of the BMT work areas, and verified that no other weld rod was left unattended.
RESPONSE TO NOTICE OF VIOLATION DATED FEBRUARY 4, 1980 Page Four SAN ONOFRE UNITS 2&3 2.
Corrective Steps which Will be Taken to Avoid Further Violations Since this incident, BMT has conducted and documented training for all of their San Onofre Units 2 and 3 site personnel, in the area of proper electrode handling practices.
Bechtel Quality Assurance personnel will continue to perform surveillance of BMT in this area.
3.
Date by Which Compliance Will be Achieved Full compliance was. achieved on January 14, 1980, when it was verified that BMT personnel had been re-instructed on the proper handling of welding electrodes.
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