ML19350E448

Responds to NRC 810423 Ltr Re Violations Noted in IE Insp Repts 50-361/81-04 & 50-362/81-01.Corrective Actions: Cabinets Reinspected to Verify Proper Cable Separation & Nonconformance Repts Generated

ML19350E448
Person / Time
Site:	San Onofre
Issue date:	05/14/1981
From:	Papay L SOUTHERN CALIFORNIA EDISON CO.
To:	Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML19350E444	List: ML19350E448
References
NUDOCS 8106230080
Download: ML19350E448 (4)

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b Southem Califomia Edison Company 3' .i;;;

RO. BOX 800 2244 WALNUT GROVE AVENUE ROGEME AD, CALarORNfA 98770 May 14, 1981 " ' * " " * "

Mr. R. H. Engelken, Director Office of Inspection and Enforcement g@ , gv i.y .

U. S. NucJear Regulatory Commission Region V

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Subject:

Docket Nos. 50-361 and 50-362 San Onofre Nuclear Generating Station,-Units 2 and 3 In a letter from your office dated April 23, 1981 we were requested to respond to a Notice of Violation result-ing from inspections of San Onofre Urit 2 construction activ-ities which took place during the pe:iod March 3 6, 1981.,

The condition described by the Notice of Violation involved failure to meet specification requirements for physical separation of safety related electrical cables.

The actions taken to correct and to prevent recur-rence of this condition are described in Attachment 1 to this 1cteer. I trust the attachment responds adequately to all aspects of the Notice of Violation. If you have any questions, or if we cen provide additional information, please let me know.

Subscribed on this /'/M day of h% , 1981 by l

07bn L. T. Papay,gice,,/I rcsident Southern Carifornia Edison Company Subscribed and sworn to before me this /f'# day of h w , 1981.

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AGNES CRABTREE

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,,,,r r,e .us 2;. Notary y6blic' in and for the County Enclosure ***' '#""8f'Los Angeles , S tate of California _

cc: R. J. Pate (NRC-San Onofre Units 2&3) 8106 23 0 Q$O . 6l-77

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• Attachment 1

. _ . RESPONSE TO FRC NOTICE OF VIOLATION J

DATED APRIL 21,.1981 Sanfonofre_ Nuclear Generating Station, Units 2 andL3 Rospon~ /to the Notice of Violation is provided below. A'atatement of the c 4dition as described by.the notice is given for reference.

NOTICE OF VIDIATION I

Docket No. 50-361 and 50-362 Construction Permit No. CPPR-97 and CPPR-98 A3?a result ofiche inspection conducted on Ma rch 3-6, 1981, and in accord-

'cnce with the Interim Enforcement Policy, 45 FR.66754 (October 7,1980),

the following~ violation was' identified: . - .

Appendix B of 10 CFR50, criterion V, as addressed in paragraph 5.1 of the-Quality Assurance Program in Appendix A'to the PSAR, states in.part: " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type _appro-priate .tcr the circumstances and shall be accoraplished in accord-ance with these instructions, procedures, or drawings...."

Bechtcl specification CS-E03, Rev. 7, " Cable Splicing, Terminations,_

and Supports",-paragraph 11.1, states in part: " Safety related (Class 1E) poeer, control and instrumentation field cables of different safety related separation groups (A, B, C or D) entering a control switchboard, equipment cabinet, panel or terminal box shall maintain s 6 inch minimum physical separation between field ,

cables of redundant safety related separation groups or field cables and internal cabinet wiring of redundant safety related separation groups...."

Contrary to the above, on March 5, 1981, the following items were identified: ,

1. In Unit 2 process instrumentation cabinet 2L188, a Class 1E ,

Channel A cable bundle from the Channel A portion of the cabinet and a Class 1E Channel B cable bundle from the Channel B portion of the cabinet were routed within two inches of each other in the lower portion of the cabinet prior to.being routed into conduits.

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Attcchment 1-Pags. 2

-e " RESPONSE ~TO NRC NOTICE OF -VIDIATION' DATED APRIL 21, 1981' . SONGS 2&3

? 2.- In Unit.3 process instrumentation cabinet 3L188, redundant Channel A and B cable hundles were within four' inches of

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each other in the lower portion of the cabinet prior to-being routed into conduits.

3. In the Unit 2 engineered safety features cabinet, two cases were. identified where.the free air space between redundant safety groups:was only four inches. In the Unit 2 reactor protection cabinet, ona case was identified where the free air space between redundant safety groups wac only one inch.

All of the above. identified items were field installed wiring.

This is a Severity Level V violation (Supplement II), applicable to both Unit 2 and Unit 3.

. RESPONSE - - J ~

1.- Corrective Steps That Have Been Taken' and Results Achieved Bechtel Quality Control personnel performed re-inspection of Nuclear Safety Related (NSR) cabinets to verify that proper Nonconformance Reports cabic separation has been maintained.

(NCRs) were generated to document and correct the Condits.ons described by the Notice and a11'other deficiencies identified during the re-inspection.

Training sessions regarding separation criteria have been con-ducted for cognizant Bechtel Quality Control and Field Engineer-ing personnel.

Construction Specification CS-E03 has been revised to clarify separation criteria.

2. Corrective Steps Which Will Be Taken

.To strengthen procedural centrols, Work Plan Procedure / Quality Control Instruction (WPP/QCI) No. 605 has been revised to establish an additional documented inspeerion of NSR cabinets or panels for separation requirements prior to area transfer to Startup.

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Attechm:nt 1-P go 3

' RESPONSE TO NRC NOTICE OF. VIOLATION

'- DATED' APRIL 21', 1981 --SONGS 2&3 This change provides for:

e Inspection of all NSR cabinets and panels to the requirements of Construction Specification CS-E03 by Field Engineering and Quality Control prior to area transfer.

e Verification by Quality Control that reparation criteria is maintained after area transfer by inspecting any additional installation of Nuclear Safety Related or non-safecy related cables in NSR cabinets or panels, e The above requirements will be subject to surveillance by Bechtel Quality Assui ance personnel to assure effective imple-mentation of these requirements.

To assure that the specified cable separation is maintained after transfer to Startup, Test Instruction Change Notice No. 315 to Test Instruction 21 (TI-21) has' been initiated to include minimum separation requirements and documentation of verification by the cognizant Startup Engineer following any startup activity involv-ing movement of-cables. Training Sessions for Startup personnel will be conducted to assure that the revisions to TI-21 are imple-mented effectively.

3. pate Whta Full Compliange Will Be Achieved The following suncarizes dates when full compliance will be (or has been) achieved:

e Procedural changes to WPP/QCI-605 were issued March 30, 1981.

e Reinspection of all NSR cabinets or panels and generation of all applicable NCRs was completed on April 9, 1981.

e Training sessions for Bechtel Quality Control and Field Engineering personnel were completed on May 5, 1981.

e, Training-sessions for craft personnel will be completed by May 12, 1981, e Uccessary changes to Construction Specification CS-E03 were completed buy 1, 1981.

e Test Instruction Change Notice No. 315 to TI-21 will be issued effective on or before May 15, 1981.

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