ML20062L503

Responds to NRC Re Violations Noted in IE Insp Repts 50-361/80-18 & 50-362/80-11.Corrective Actions:Work Plan Procedure/Qc Instruction 400 Has Been Revised to Strengthen Procedural Controls

ML20062L503
Person / Time
Site:	San Onofre
Issue date:	12/23/1980
From:	Arenal A SOUTHERN CALIFORNIA EDISON CO.
To:	Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML20062L501	List: ML20062L503
References
NUDOCS 8101300759
Download: ML20062L503 (4)

Text

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Mr. R. H. Engelken, Director ' !L@

Office of Inspection and Enforcement U. S. Nuclear Regulatory Commission Region V ]

Suite 202, Walnut Creek Plaza 1990 North California Boulevard, Walnut Creek, California 94506

Dear Mr. En:

elken

Subj ect: Docket No. 50-361 San Onofre Nuclear Generating Station, Unit 2 In a letter from your office dated December 2, 1980 we were requesced to respond to a Notice of Violation resulting from inspections of San Onofre Unit 2 construction activities which took place during the period September 23-26, 1980. The condition described by the Notice of Violation involved inad-equate cleaning of stainless steel piping prior to application of insulation. Our response is provided as Attachment 1.

I trust the _attachmen_t_r_egp.o_n_d_s ade,quately to_all aspects of the Notice of Violation. If you have any questions, or if we can provide additional information, please let.me know. . .

us_

Subscribed on this ' ' " ' '

day of December, 1980 by -

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A. Arenal Vice President Southern California Edison Company Subscribed and sworn to before me this V i' day of December, 1980.c.ecec:ccecccec;r t::coc:n /- ,

i) ~ U FCIAL SUL b) 1,f,W AGNES CRhBTREE O .u . . ;

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3.i .yl-.< W wm nne. ouram O  : Notary Public in and for the sacat omcc m dSWF o vsF --

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---W cosmsen tsa."Aas.n.198: County of Los Angeles, State m of California Enclosure cc: R. J. Pate (NRC-San Onofre Units 2&3)

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Attachment 1 RESPONSE TO NRC NOTICE OF VIOL \ TION DATED DECEMBER 2,1980 San Onofre Nuclear Generating Station, Unit 2 Response to the Notice of Violation is provided below. A state-ment of the condition as described by the notice is given for reference.

NOTICE OF VIOL \ TION Docket No. 50-361 Construction Permit No. CPPR-97 As a result of the inspection conducted on September 23-26, 1980, and in accordance with the Interim Enforcement 'olicy, 45 FR 66754 (October 7,1980), the following violatioi w~s identified:

Appendix B of 10CFR50, Criterion V, as implemented by paragraph 3.1 of the Quality Assurance Program doctimt.tced in Appendix A to the PSAR requires that." Activities affect-ing quality shall be prescribed by documented instructions.

procedures, or drawings, of a type appropriate to the circum-stances and shall.be_ accomplished _.in accordan.ce..wi.th_these _.

instructions, procedures, or drawings...." - - '

The Bechtel Specification No. CS-P204, " Field Fabrication and Erectica of Nuclear Piping to ASME Section III.and m.

LP - Field Fabrication and Erection of Auxiliary _ Boiler External

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Piping to .iSME Section I," paragraph 9.2.3.1 states, in part, that "...The exterior surface of ... stainless steel piping shall be c1 caned in accordance with Procedure No. 18 of the Piping Material Classifications, Drawin3 No. 90004. Only stainless steel piping which will be insalated shall be cleaned."

Bechtel Procedure No. 18, " Field Procedure for Cleaning External Surfaces of Stainless Steel. Piping" requires that the pipe cleaning include manual cleaning to remove foreign matter prior to insulating.

Contrary to the above, on September 25, 1980, stainless steel piping spools Nos. 2S-S1-045 and -046 of the safety injection ,

system were being insulated although are strikes, weld splatter, and tape residue remained on the external surfaces of the piping.

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_ This is a Severity Level IV violation (Supplement1 .._= II). _._

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Attachment 1-Page 2 RESPONSE TO NRC NOTICE OF VIOLATION DATED DECEMBER 2,1980 San Onofre Nuclear Generating Station, Unit 2

RESPONSE

1. Corrective Steps Which Have Been Taken und Results Achieved The conditions stated above were investigated by Bechtel Quality Control personnel, and it was determined that the

" Physical Items" such as are strikes were found to be within acceptable parameters. However,.it has been confirmed that a cleanliness problem did exist for Stainless Steel Quality Class I and II Piping.

The two (2) site thermal insulation installation contractors (Thorpe and Transco) have been notified of the requirements of rinsing the exterior surfaces of stainless steel piping with demineralized water, manual cleaning consisting of wire brushing and scraping, and solvent cleaning to remove oil, grease or other soluble foreign matter.

To s trengthen procedural controls, Work Plan Procedure / Quality Centrol Instruccion (WPP/QCI) No. 400 has been revised. This procedure provides instructions for the establishment-of an inspection program for all Quality Class I and II Stainless Steel Pipe Lines for cleanness and mechanical. defects,_with the following highlights: _ . _ - .

7 A requirement '~that " exterior ~ surface ~of ~s tainle~ss~ steel ~ ~ ~

pipe requiring thermal insulation shall be cleaned in accordance with Construction Specification CS-P204 and .-

"" Procedure No. 18 of the Pipe Material Classification,.

Drawing No. 90004, prior to insulation installation.

a A documented inspection by Bechtel Quality Control aersonnel for cleanness and mechanical defects.

2 A documented Release of stainless steel piping for thermal insulation installation.

o A requirement that pipe insulation installation must be accomplished within five (5) working days of the delivery of the Release to the insulation contractor or a new inspection and release will be initiated.

e A requirement that the Bechtel Piping Construction Field Engineer and Quality Control Engineer monitor the insula-tion installation areas tofensure pipe cleanliness.

.__2_ . c . The above requirements have been the subject of surveillance 2 .' Z ,

--..; byBechtelQualityAssurancepersonnel,withsatisfactoryreshlts.

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Attachment 1 - Page 3 RESPONSE TO URC NOTICE OF VIOLATION DATED DECEMBER 2, 1980 San Onofre Nuclear Generating Station, Unit 2

2. Corrective Steos khich Will Be Taken

-Quality Class I and 11 stainless steel piping insulation accomplished prior to the release of the above procedural changes will have the insulation removed, re-cleaned if necessary, and the cleanliness verified prior to reinsula-tion. -

3. Date Bv hhich Comnliance Will Be Achieved All necessary procedural changes were issued and implemented-on Octooer 17, 1980.

Re-inspection of previously insulated Quality Class I and 11 stainless steel piping will be accomplished prior to fuel load of Unit No. 2 c

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