ML20009B289

Responds to NRC 810427 Ltr Re Violations Noted in IE Insp Rept 50-361/81-05.Corrective Actions:Cable Pulling General Foreman & Craft Personnel Trained on Requirement for Cable Handling

ML20009B289
Person / Time
Site:	San Onofre
Issue date:	05/13/1981
From:	Papay L SOUTHERN CALIFORNIA EDISON CO.
To:	Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20009B285	List: ML20009B289
References
NUDOCS 8107150232
Download: ML20009B289 (5)

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DN 50-361 Southern California Edison Company i g5 P O. BOX 800 2244 WALNUT GROVE AVENUE 7, pgpy ROSEMEAD, CALWORNIA 91770 vice entsionse' 363 372 5474 May 13, 1981 A s.

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Mr. R. H. Engelken, Director C

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Office of Inspection and Enforcement 4 gv U. S. Nuclaar Regulatory Commission Region V

%Q[ g Suite 202, Walnut Creek Plaza QTG3/

1990 North California Boulevard Walnut Creek, California 94506

Subject:

Docket Nos. 50-361, S M San Onofre Nuclear Generating Station, Units 2 and 3 In a letter from your office dated April 27, 1981 you forwarded two enforcement Notices resulting from inspec-tions of San Onofre Units 2 and 3 construction activities which took place during the period February 14 to March 12, 1981. The conditions described by the Notices involved:

(a) inadequate protection of electrical cables to prevent physical damage and, (b) inadequate housekeeping as evi-denced by observation of a Startup Engineer smoking in an area designated as non-smoking.

l Attachments 1 and 2 to this letter describe the actions taken to correct and prevent recurrence of these condi-tions. I trust these attachments respond adequately to all aspects of the Notices. If you have any questions or if we can provide additional information, please let me know.

Very truly yours, 1

Attachments

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R. J. Pate (NRC-San Onofre Units 2 and 3) 8107150232 8107o1 gDRADOCK 05000361 PDR 21 'Rc

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/\Y s\ -\f RESPONSE TO NRC NOTICE OF VIDIATION DATED APRIL 27, 1981f D r$nf p: son eo yd San Onofre Nuclear Generating Station, Unit 2 M m@ v I$

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A statement bY3'

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the condi. tion as described by the notice is given for reference.

NOTICE OF VIOLATION Southern California Edison Co. Docket No. 50-361 As a result of an NRC inspection on February 14, to March 12, 1981, and in accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7,1980), the following violation was identified.

Appendix 3 of 10CFR 50, Criterion V, states, in part, that,

" Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings,...and shall be accom-plished in accordance with these instructions, procedures, or drawings".

Bechtel construction procedure WPP/QCI 008, states that electrical cable will be stored in accordance with ANSI N45.2.2, paragraph 2.7. ANSI N45.2.2, paragraph 2.7.4 states in part, " Items classified to level D (this includes electrical cables) . . . require protection against. . . physical damage". ,

Contrary to the above, cables 3ARLO3206 and 3ARLO3207 were observed lying on the control room floor and being walked on by persons working in that area on February 11, 1981 and Feb-ruary 18, 1981. On February 17, 1981, these same cables were observed coiled and attached to scaffolding in the control room in a manner which violated the minimum bend radius of 11 inches.

This is a Severity Level VI violation (Supplement).

1. Corrective Steps Which Have Been Taken and Results Achieved The conditions described by the notice were identified on Noncon-formance Reports and were investigated by Bechtel Quality Control personnel. Cables 3ARLO3206 and 3ARLO3207 were visually inspected and Hi-pot tested and the results were found to be within accept-ance limits.

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itESpONSE TO *1GC NOTICE OF VIDIATION Attachmnt 1 - Page 2 DATED APRIL 27, 1981 - SONGS 2 ,

The following actions were taken to assure proper protection of l cables during construction activities

o Cable pulling general foremen and craft personnel were trained on the requirement for cable handling.

o Units 2 rud 3 were walked down by craft personnel to provide protect'on of cables not adequately protected.

1 o Direction was provided to cognizant personnal from Bechtel

Field Engineering and Construction Management to protect cabling from hazards during installation activities.

2. Corrective Steps Which Will Be Taken o Weekly documented housekeeping surveillances by Quality Control personnel will provide special monitoring for propor protection

of cables, f

o Effective implementation of the above requirements will be verified through surveillance activities by Bechtel Quality

, Assurance personnel.

3. Date When Full Compliance Will Be Achieved l Full compliance was achieved by May 12, 1981. By this date cognizant personnel had been re-instructed, walkdown had been i completed, and adequate protection for cable in storage was achieved.

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. . u, Attachment 2 RESPONSE TO NRC NOTICE OF DEVIATION DATED APRIL 27, 1981 San Onofre Nuclear Generating Station, Unit 2 Response to the Notice of Deviation is provided below. A statement of the condition as described by the notice is given for reference.

NOTICE OF DEVIATION Southern California Edison Company Docket No. 50-361 Based on the results of an NRC inspection conducted on Feb-ruary 14, to March 12, 1981, it appears that one of your activ-ities was not conducted in accordance with your commitments in App,ndix 3A of the FSAR which states that "The Q2ality Assurance Program for safety-related items regarding hous2 keeping require-ments for the control of work activities, conditions, and environ-ments at the plant are in accordance with ANSI N45.2.3.1973, as interpreted by Regulatory Guide 1.39."

ANSI N45.2,3.1973, paragraph 3.1, states that areas for specific activities, shall be assigned and regulated. In paragraph 2.1, l

Zone IV is defined as a no-smoking area.

Contrary to the above, on February 22, 1981, the NRC inspector observed a Startup Test Engineer smoking in the Diesel Generator Building which is a Zone IV (No-Smoking) area. Also, there were several extinguished cigarettes on the floor.

This is a deviation.

RESPONSE

1. Corrective Steps Which Have Been Taken and Results Achieved .

The condition described in the Notice of Deviation was identified in Corrective Action Request S023-F-1024 dated February 27, 1981.

As immediate remedial action the Project Startup Engineering Supervisor counseled the involved Startup Engineer relative to the requirements of WPP/QCI-009 far Housekeeping and in the observance of all posted signs. As a more generic corrective action to prevent recurrence, copies of WPP/QCI-009, Rev. 8, i

Section 4.7 have been distributed to SCE Startup Supervision with a cover letter requiring that they review this condition with personnel under their direct supervision. Review by Startup personnel has been documented by individual signatures on informa-tion acknowledgment sheets.

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' - .' RESP 0NSE TO NRC NOTICE OF DEVIATION Attachment 2 - Page 2 DATED APRIL' 27, 1981 - SONGS 2

2. Corrective Steps Which Will Be Taken No further Corrective Steps are required. Quality Assurance will perform Surveillance to verify effectiveness of corrective steps taken.

3. Date When Steps to Correct the Deviation Will Be Completed Corrective Steps were completed on April 6, 1981 when Startup personnel completed review cf housekeeping requirements.

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