ML20205M683

Notice of Violation from Insp on 850923-27.Violations Noted: Galite Thermocouple Extension Cable Files Did Not Establish Similarity Between Plant Equipment & Test Specimen

ML20205M683
Person / Time
Site:	San Onofre
Issue date:	04/02/1986
From:	Thomas Young NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20205M665	List: IR 05000206/1985030 ML20205M683
References
50-206-85-30, 50-361-85-29, 50-362-85-28, NUDOCS 8604150346
Download: ML20205M683 (6)

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APPENDIX A

NOTICE OF VIOLATION

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Southern California Edison Company Docket Nos. 50-206, 50-361 and 50-362-2244 Walnut Grove Avenue License Nos. DPR-13, NPF-10 and NPF-15 Rosemead, California 91770 i As a result of the inspection conducted on September 23-27, 1985.and in accordance with the NRC Enforcement Policy (10 CFR.Part 2, Appendix C), the j following violations were identified:

1. Paragraph (j) of 10 CFR 50.49 requires that a record of qualification must be maintained to permit verification-that each item is qualified.

for its application and meets its specified. performance requirements-

) when subjected to the conditions predicted to be present when it must j perform its safety function up to the end of its qualified life.

Paragraph (k) of 10 CFR 50.49 states that equipment previously required by the Commission to be qualified to the " Guidelines for Evaluating Environmental Qualification for Class 1E Electrical Equipment in Operating Reactors" or NUREG-0588, " Interim Staff Position on 1

Environmental Qualification of Safety-Related Electrical Equipment" need

) not be requalified.

l

) a. Section 5.2.2 of the Guidelines states that the type test is only

valid for equipment identical in design and material construction to thr. test specimen, and any deviations should be evaluated as part of the documentation. (Applicable to Unit 1) i b. Section 5(1) of NUREC-0588 (Cat. I and II) states that the basis of I

qualification shall show the relationship of all facets of proof j needed to support adequacy of the complete equipment. (Applicable to Units 2 and 3). '

Contrary to the above requirements, for Galite thermocouple extension i

cable, at the time of the inspection, the files did not establish similarity between the plant equipment'and test specimen;'specifically, the processes for applying insulation to the conductors were not shown to be similar. "" #.

This is a Severity Level IV violation (Supplement I).

j 2. Paragraph (j) of 10 CFR 50 49 requires that a record of qualification

'j must be maintained to permit verification that each item is qualified for its appliention and meets its specified performance requirements when

! subjected to the conditions predicted to be present when it must perform j its safety function up to the end of its qualified' life.

i

' Contrary to the above requirement, for Rockbestos Firewall EP cable.

j at the time of the inspection, the fil,es did not adequately support claimed qualification to 10 CFR 50.49;,)specifically, the test report relied on for qualification was Rockbeston Report QRf1804, which

{ is discredited by IE Information Notice 84-44.

This-is.a Severity Level IV violation (Supplement I).

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3. Paragraph (j) of 10 CFR 50.49 requires that a record of qualification must be maintained to permit verification that each item is qualified for its application and meets its specified performance requirements when subjected to the conditions predicted to be present when it must perform its safety function up to the end of its qualified life.

Paragraph (k) of 10 CFR 50.49 states that equipment previously required by the Commission to be qualified to the " Guidelines for Evaluating Environmental Qualification for Class 1E Electrical Equipment in Operating Reactors" need not be requalified.

Section 5.2.5 of the Guidelines states that operational modes tested shall be representative of the actual application requirements; components which operate normally energized in the plant should be normally energized during the tests.

Contrary to the above requirementa, for Target Rock solenoid valve SV 119, at the time of the inspection the files did not determine qualified life 3

based on normal energization; instead life was determined without consideration for self heating effects that subatantially reduced the life.

This is a Severity Level IV violation (Supplement I).

4. Paragraph (j) of 10 CFR 50.49 requires that a record of qualification must be maintained to permit verification that each item is qualified for its application and meets its specified performance requirements when subjected to the conditions predicted to be present when it must perform its safety function.

Paragraph (k) of 10 CFR 50.49 states that equipment previously required by the Commission to be qualified to the " Guidelines for Evaluating Environmental Qualification for Class IE Electrichl Equipment in Operating Reacters" need not be requalifiea.

Section 5.1 of the Guidelines requires that as a minimum the qualification for severe temperature, pressure, and steam service conditions should be based on type testing.

Contrary to the above requirements, for Honeywell E/P transducer FCV 1115D, at the time of the inspection, qualification for a steam environment was based entirely as analysis 9with no type test.

This is a Severity Level IV violation (Supplement I).

5. Paragraph (j) of 10 CFR 50.49 requires that a record of qualification must be maintained to permit verification that each item is qualified for 1 its application and meets its specified performance requirements when subjected to the conditions predicted to be present when it must perform its safety function Paragraph (k) of 10 CFR 50.49 states that equipment previously required by the Commission to be qualified to NUREG-0588, " Interim Staff Position. ,

on Environmental Qualification of Safety-Related Electrical Equipment" {

need not be requalified.

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Section 2.2(7) of NUREG-0588 Cat. II states that performance characteristics should be verified during testing throughout the range of required operability.

Section 2.1(1) of NUREG-0588 Cat. Il invokes the qualification method criteria of IEEE Standard 323-1971, which states in Section 5.2.3.4 that the type test data shall contain the static and dynamic performance characteristics.

Contrary to the above requirements, for Rockbestos Firewall III cable, at the time of the inspection:

a. The files did not adequately support claimed qualification to 10 CFR 50.49; specifically, the test report relied 'sn for qualification was Rockbestos Report QRf1803, which is discreditr.d by IE Information Notice 84-44.

b. The files did not contain test data relevant *.o the required operating performance characteristics in the plant.

This is a Severity Level IV violation (Supplement I).

Pursuant to the provisions of 10 CFR 2.201, the Southern California Edison Company is hereby required to submit to this office within thirty days of the date of this Notice, a written statement of explenation in reply, including:

(1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further violations; and (3) the date when full compliance will be achieved. Consideration may be given to extending your response time for good cause shown.

/JR 2 1986 '

Dated T7" Young,Jr.,C(iNijf (

Engineering Sect (

I i

APPENDIX A NOTICE OF VIOLATION Southern California Edison Company Docket Nos. 50-206, 50-361 and 50-362 2244 Walnut Grove Avenue License Nos. DPR-13, NPF-10 and NPF-15 Rosemead, California 91770 As a result of the inspection conducted on September 23-27, 1985 and in accordance with the NRC Enforcement Policy (10 CFR Part 2, Appendix C), the following violations were identified:

1. Paragraph (j) of 10 CFR 50.49 requires that a record of qualification must be maintained to permit verification that each item is qualified for its application and meets its specified performance requirements when subjected to the conditions predicted to be present when it must perform its safety function up to the end of its qualified life.

Paragraph (k) of 10 CFR 50.49 states that equipment previously required by the Commission to be qualified to the " Guidelines for Evaluating Environmental Qualification for Class 1E Electrical Equipment in Operating Reactors" or NUREG-0588, " Interim Staff Position on Environmental Qualification of Safety-Related Electrical Equipment" need not be requalified.

a. Section 5.2.2 of the Guidelines states that the type test is only valid for equipment identical in design and material construction to the test specimen, and any deviations should be evaluated as part of the documentation. (Applicable to Unit 1)

b. Section 5(1) of NUREG-0588 (Cat. I and II) states that the basis of a

qualification shall show the relationship of all facets of proof needed to support adequacy of the complete equipment. (Applicable to Units 2 and 3).

Contrary to the above requirements, for Calite thermocouple extension cable, at the time of the inspection, the files did not establish similarity between the plant equipment and test specimen; specifically, the processes for applying insulation to the conductors were not shown to be similar.

This is a Severity Level IV violction (Supplement I).

2. Paragraph (j) of 10 CFR 50749 requires that a record of qualification -

must be maintained to permit verification that each item is qualified for its application and meets its specified performance requirements when subjected to the conditions predicted to be present when it must perform its safety function up to the end of its qualified life.

Contrary to the above requirement, for Rockbestos Firewall EP cable, at the time of the inspection, the files did not adequately support claimed qualification to 10 CFR 50.49; specifically, the test report relied on for qualification was Rockbestos Report QRil804, which

. is discredited by IE Information Notice 84-44.

This is a Severity Level IV violation (Supplement I).

2

3. Paragraph (j) of 10 CFR 50.49 requires that a record of qualification must be maintained to permit verification that each item is qualified for its application and meets its specified performance requirements when subjected to the conditions predicted to be present when it must perform its safety function up to the end of its qualified life.

Paragraph (k) of 10 CFR 50.49 states that equipment previously required by the Commission to be qualified to the " Guidelines for Evaluating Environmental Qualification for Class IE Electrical Equipment in Operating Reactors" need not be requalified.

Section 5.2.5 of the Guidelines states that operational modes tested shall be representative of the actual application requirements; components which operate normally energized in the plant should be normally energized during the tests.

Contrary to the above requirements, for Target Rock solenoid valve SV 119, at the time of the inspection 3 the files did not determine qualified life based on normal energization; instead life was determined without consideration for self heating effects that substantially reduced the life.

This is a Severity Level IV violation (Supplement I).

4. Paragraph (j) of 10 CFR 50.49 requires that a record of qualification must be maintained to permit verification that each item is qualified for its application and meets its specified performance requirements when subjected to the conditions predicted to be present when it must perform its safety function.

Paragraph (k) of 10 CFR 50.49 states that equipment previously required by the Commission to be qualified to the "Guidelit.es for Evaluating Environmental Qualification for Class 1E Electrical Equipment in Operating Reactors" need not be requalified.

Section 5.1 of the Guidelines requires that as a minimum the qualification for severe temperature, pressure, and steam service conditions should be based on type testing.

Contrary to the above requirements, for Honeywell E/P transducer FCV 1115D, at the time of the inspection, qualification for a steam environment was based entirely as analysis Nith no type test.

This is a Severity Level IV violation (Supplement I).

5. Paragraph (j) of 10 CFR 50.49 requires that a record of qualification must be maintained to permit verification that each item is qualified for its application and meets its specified performance requirements when subjected to the conditions predicted to be present when it must perform its safety function Paragraph (k) of 10 CFR 50.49 states that equipment previously required by the Commission to be qualified to NUREG-0588, " Interim Staff Position on Environmental Qualification of Safety-Related Electrical Equipment" need not be requalified.

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Section 2.2(7) of NUREG-0588 Cat. II states that performance characteristics should be verified during testing throughout the range of required

operability.

L Section 2.1(1) of NUREG-0588 Cat. II invokes the qualification method criteria of IEEE Standard 323-1971, which states in Section 5.2.3.4 that the type test data shall contain the static and dynamic performance characteristics.

, Contrary to the above requirements, for Rockbestos Firewall III cable, at the time of the inspection:

a. The files did not adequately support claimed qualification to 10 CFR 50.49; specifically, the test report relied on for qualification was Rockbestos Report QRf1803, which is discredited by IE Information Notice 84-44.

[ b. The files did not contain test data relevant to the required i operating performance characteristics in the plant.

This is a Severity Level IV violation (Supplement I).

Pursuant to the provisions of 10 CFR 2.201, the Southern California Edison Company is hereby required to submit to this office within thirty days of the date of this Notice, a written statement of explanation in reply, including:

1 (1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further violations; and

(3) the date when full compliance will be achieved. Consideration may be given to extending your response time for good cause shown, i

I fh na 2 Dated less g  ; g,

'} T7' Young,Jr.,CQ(f ( _//

Engineering SectiM (i V e

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