ML20009E117
| ML20009E117 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 07/09/1981 |
| From: | Wagner W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20009E116 | List: |
| References | |
| 50-206-81-22, NUDOCS 8107270127 | |
| Download: ML20009E117 (3) | |
Text
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I Southern California Edison Company P. O. Box 800 2244 Walnut Grove Avenue j
Rosenead, California 91770 1
l Docket flo. 50-206 j
License ?!o. DPR-13 l
APPErlDIX A NOTICE OF VIOLATION i
As a result of the inspection conducted on June 2-5, 1981, and in accordance I
with the Interim Enforcement Policy, 45 FR 66754 (October 7,1980), the following violations were identified:
I A.
10 CFR 50 Appendix B. Criterion IX, states in part: " Measures shall he established to assure that special processes, including... nondestructive testing, are controlled and accomplished by qualified personnel using qualifled procedures in accordance 41th applicable codes...."
l Design Change 80 Safety and Environment.?.1 Analysis for Addition of !!echanical 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
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class.Section III of the ASME Boiler and Pressure Vessel Code will l
be applied...."
Applicable Design Drawing No. 235398 - Sphere Penetration Sample Line Cap No. B16A & B states, in part: " Field weld...per ASME...Section l
III, subsection NE, Cat. B. radiograph required."
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ASME B&PV Code, Sect 4n III, subsection HE, requirement NE-5111 states. -
l in part:
... Radiographic examination shall be in accordance with i
Su tton V, Article 2...."
ASitE B&PV Code,Section V, Article 2. requirement T-263(a), states l
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
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density through the body of the penetrameter...then an additional s
penetrameter shall be used L.r each exceptional area or areas and N
i the radiograph retaken."
i 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."
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8107270127 010709 l
PDR ADOCK 05000206 O
PDR l
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. 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."
l 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 i
I aa 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 I
had been placed on film side of the parts, and (3) the radiographs I
showed weld ripples that could mask discontinuities that may be present l
in the welds.
This is a Severity Level V Violation (Supplement II).
B.
10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings states:
" Activities affecting quality shall be prescribed i
by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with s
these instructions, procedures, or drawings.
Instructions, procedures, N
or drawings shall include appropriate quantitative or qualitative i
acceptance criteria for detennining that important activities have been satisfactorily accomplished."
1.
Southern California Edison Doctznent AD12-A, Project General Design Criteria Manual, defines governing design criteria applicable to changes to the San onofre fluclear 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 i
designed systems and equipinent, previously established with newly (FSAR and amendments) for San Onofre Unit 1 shall apply criteria throughout the existing systems including the interface point.
Beyend 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 flo. 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 l
require.nents of NRC Regulatory Guide 1.75 unless otherwise specified."
Regulatory Guide 1.75 adopts IEEE Standard 334.
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I l The Design Criteria Manual also states in paragraph 4.2 "The control systems, equipment and components shall comply with the applicable criteria, codes,nd 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 minine 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 between Class IE 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 recomendation imlementation 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).
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 insection, torque testing, and documentation of anchor installation.
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 docue ntation.
This is a Severity Level V Violation (Supplement II).
Pursuant to the provisions of 10 CFR 2.201, Southern California Edison Company is hereby required to submit to this office within twenty-five days of the date of this Notice, a written statement or explanation in results achieved; Q; ) corrective steps which will be taken to avoid further reply including:
the corrective steps which have been taken and the
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items of noncompliance; and (3) the date when full compliance will be achieved.
Consideration may be given to extending your response time for good cause shown. Under the authority of Section 182 of the Atomic Energy Act of 1954, as anended, this response shall be submitted under oath or affimation.
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Dated JUL 9 1981 MbO3 [ MN W. J. Wagner, Reactor Inspector
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