ML20199E821
| ML20199E821 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 06/18/1986 |
| From: | Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Baskin K SOUTHERN CALIFORNIA EDISON CO. |
| Shared Package | |
| ML20199E825 | List: |
| References | |
| TAC-42516, NUDOCS 8606240096 | |
| Download: ML20199E821 (3) | |
See also: IR 05000206/1985030
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JUN 181986
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Docket Nos. 50-206, 50-361 and 50-362
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Southern California Edison Company
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P. O. Box 800
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2244 Walnut Grove Avenue:
Rosemead, California '9177,0
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Attention:
Mr. Kenneth P.'Baskin,'Vice President
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Nuclear Engineering, Safety and Licensing Department
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Gentlemen:
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Thank you for your letter. dated May 9,1986, informing us of the steps you
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have taken to correct the ' items'which we brought to your attention in our
letter _ dated April 2, 1986. Enclosed are our comments on'your response and
we still consider all five Severity Level IV violations remain valid. Your
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corrective actions will be verified during a future inspection.
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Your cooperation with us is appreciated.
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Sincerely,
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Orlpinoi signe'd b'y
D. 'F."KEfifdh, Director
Division of Reactor Safety
and Projects
Enclosure:
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As stated
bec w/ enclosure & cy ltr dtd 5/9/86:
RSB/ Document Control Desk (RIDS)
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Project Inspector
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Resident Inspector
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G. Cook
B. Faulkenberry
J. Martin
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State of California
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Region V
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ADOCK 05000206
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COMMENTS ON SOUTHERN CALIFORNIA
EDIS0N LETTER OF MAY 9, 1986
The licensee's letter of May 9,1986 responded to the Notice of Violation of
the subject equipment qualification inspection as transmitted by the NRC
letter of April 2,1986. The notice contains five Severity Level IV viola-
tions. After reviewing the response, we conclude that all five items remain
at Severity Level IV; however, the corrective actions are considered accep-
table and subject to verification of them, the items may be closed.
Each of the five violations involves failure to have in place, at the time of
the inspection in September 1985, documentation fully establishing the environ-
mental qualification of equipment installed in the plants. Details of the
violations are provided in the inspection report and Notice of Violation. The
following comments address specific points raised in the licensee's May 9
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response,
1.
Galite cable - The file based qualification to 00R Guidelines and NUREG 0588 Category II on type testing of cable manufactured by a different
supplier using identical fluoropolymer insulation material. Although the
licensee states that all manufacturers conform to the proprietary process
furnished by the insulation polymer supplier, not all of the process
conditions utilized in the manufacture of cable are defined in detail by
the polymer supplier.
Variations among cable manufacturers' processes
could result in differences such as bonding of the insulation to the
cable conductors, wall thicknesses, or even the use of fillers or adders,
that could affect cable qualification. The licensee's response states
that the cable manufacturer was contacted during the inspection and
additional information was obtained which adequately demonstrates simi-
larity of the two manufacturers' processes. Although the NRC inspectors
have not reviewed that information, we agree that subject to our verifi-
cation its incorporation into the documentation files may be sufficient
to complete qualification of the Galite cable to the D0R Guidelines and
NUREG 0588 Category II.
2.
Rockbestos Firewall EP cable - The file based qualification on a Rockbestos
test report discredited by IE Information Notice 84-44. The 1.icensee
states that IN 84-44 does not say that the cable is not qualified, and
that it states no immediate safety problem exists and that the licensee
is responsible for ensuring qualification for the intended use.
does state that the relevant Rockbestos qualification programs contained
deficiencies so severe that they could not adequately demonstrate qualifi-
cation; that user utilities are responsible for reviewing the IN and taking
applicable corrective action to ensure the qualification of Rockbestos
cable installed in their plants; and that this review is part of an effort
to meet the deadline and requirements set forth in 10 CFR 50.49.
IN 84-44 also suggests possible courses of corrective action, one of which
is to obtain data from other available qualification tests. The licensee's
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response states that this course was followed as a result of the audit, and
subject to our verification it may well be a satisfactory approach. The
licensee's prior actions--following the course of Rockbestos retesting--
were not sufficient to establish qualification in a timely manner.
3.
Target Rock solenoid valve - The deficiency involves failure to consider
the effects of self-heating on qualified life. We do not dispute the
licensee's statement that this equipment was considered qualified at the
time of the inspection, since the concern involves an apparent oversight,
and the licensee does not dispute the existence of a violation.
Subject
to our verification, the corrective actions identified in the licensee's
response are considered fully responsive.
4.
Honeywell E/P transducer - The file claimed qualification for a steam
environment based on analysis, with no type test. During the inspection
the licensee stated that the document package summary sheets contained an
error, and in fact the only harsh environmental parameter is radiation.
The licensee's response states that, although an error was made in documenting
the environmental conditions, the equipment really was qualified.
In fact,
the licensee's qualification documentation was deficient because it did not
adequately establish qualification for the defined environment conditions.
Simply stated, the licensee did not meet his burden of documenting qualifi-
cation of the equipment. Subject to our verification, the indicated
corrective action is acceptable.
5.
Rockbestos Firewall III cable - This violation is similar to item 2 above.
It differs in that additional test data were subsequently obtained from
Rockbestos, rather than from another licensee. The same comments apply.
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