IR 05000206/1985030: Difference between revisions

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{{Adams
{{Adams
| number = ML20199E821
| number = ML20205M661
| issue date = 06/18/1986
| issue date = 04/02/1986
| title = Ack Receipt of 860509 Ltr Informing NRC of Steps Taken to Correct Violations Noted in Insps 50-206/85-30,50-361/85-29 & 50-362/85-28.Comments Encl.All Severity Level IV Violations Remain Valid
| title = Discusses Insp Repts 50-206/85-30,50-361/85-29 & 50-362/85-28 on 850923-27 & Forwards Notice of Violation
| author name = Kirsch D
| author name = Kirsch D
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Line 10: Line 10:
| license number =  
| license number =  
| contact person =  
| contact person =  
| document report number = TAC-42516, NUDOCS 8606240096
| document report number = NUDOCS 8604150341
| package number = ML20199E825
| package number = ML20205M665
| document type = CORRESPONDENCE-LETTERS, NRC TO UTILITY, OUTGOING CORRESPONDENCE
| document type = CORRESPONDENCE-LETTERS, NRC TO UTILITY, OUTGOING CORRESPONDENCE
| page count = 3
| page count = 6
}}
}}


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APR 2 1986 Docket Nos. 50-206 50-361 50-362 Southern California Edison Company 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Attention: Mr. Kenneth P. Baskin, Vice President Nuclear Engineering, Safety and Licensing Department Gentlemen:
,     JUN 181986 i
Subject: NRC Enforcement Actions Related to Inspection Nos. 50-206/85-30; 50-361/85-29; and 50-362/85-28 A team inspection was conducted by Mr. R. C. Wilson and other NRC representatives on September 23-27, 1985, at the San Onofre Nuclear Generating Station of activities authorized by NRC License Nos. DPR-13, NPF-10 and NPF-15. The team's findings were discussed with you and members of your staff at the conclusion of the inspection and documented in Inspection Report Nos. 50-206/85-30, 50-361/85-29, and 50-362/85-2 The inspection included reviews of your implementation of a program required by 10 CFR 50.49 for establishing and maintaining.the qualification of electric equipment within the scope of 10 CFR 50.49. 'The inspection aise included evaluation of your actions concerning EQ-related operating license conditions for Units 2 and Based on the results of the inspection, it appears that certain of your activities were not conducted in full compliance with NRC requirements, as set forth in the Notice of Violation, enclosed herewith as Appendix Your response to this Notice is to be submitted in accordance with the provisions of 10 CFR 2.201 as stated in Appendix A, Notice of Violatio ,
!
In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosure will be placed in the NRC Public Document Roo Should you have any questions concerning this Notice, we will be glad to discuss them with yo PDR G
!  Docket Nos. 50-206, 50-361 and 50-362
ADOCK 05000206 PDR    h
 
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APR'2 1986 SouthernCaliforniaEdisonCompany.' 2
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The responses-directed by this letter and.'the accom'panying Notice are not subject to the clearance procedures of the': Office of Management and Budget'-
      ~
as required by the Paperwork Reduction Act of 1980, PL 96-51 ;
 
Sincerely,
.
.
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      '
, Southern California Edison Company '
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P. O. Box 800  , r 2244 Walnut Grove Avenue:
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Rosemead, California '9177,0
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Fa D. F. Kirsch, Director Division of Reactor Safety and Projects l
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===Enclosure:===
,
A. Notice of Violation
 
REGION V S &    1450 MARlA LANE,SulTE 210 U    WALNUT CREEK, CAllFORNI A 94596
  %.'....o          -
APR 2 19 i6 Docket Nos. 50-206 50-361 50-362 Southern California Edison Company 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Attention: Mr. Kenneth P. Baskin, Vice President Nuclear Engineering, Safety and Licensing Department Gentlemen:
Subject: NRC Enforcement Actions Related to Inspection Nos. 50-206/85-30; 50-361/85-29; and 50-362/85-28 A team inspection was conducted by Mr. R. C. Wilson and other NRC representatives on September 23-27, 1985, at the San Onofre Nuclear Generating Station of activities authorized by NRC License Nos. DPR-13, NPF-10 and NPF-15. The team's findings were discussed with you and members of your staff at the conclusion of the inspection and documented in Inspection Report Nos. 50-206/85-30, 50-361/85-29, and 50-362/85-2 The inspection included reviews of your implementation of a program required by 10 CFR 50.49 for establishing and maintaining the qualification of electric equipment within the scope of 10 CFR 50.49. The inspection also included evaluation of your actions concerning EQ-related operating license conditions for Units 2 and Based on the results of the inspection, it appears that certain of your activities were not conducted in full compliance with NRC requirements, as
;
set forth in the Notice of Violation, enclosed herewith as Appendix Your response to this Notice is to be submitted in accordance with the provisions of 10 CFR 2.201 as stated in Appendix A, Notice of Violatio In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosure will be placed in the NRC Public Document Roo Should you have any questions concerning this Notice, we will be glad to discuss them with yo _ - - _ - _ _ _ _ _ _ _ _ _ _ _ . _  _ - _ _ _ - -. _ _ _ _ - - - - - . _ _ - _ _ _ _ _ _ __- _ --___-___ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ - - _ _ _ _
 
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APR 2 1986 Southern California Edison Company 2
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r-The responses directed by this letter and the accompanying Notice are not
.;     subject to the clearance procedures of the Office of Management and Budget    .


l  Attention:  Mr. Kenneth P.'Baskin,'Vice President Nuclear Engineering, Safety and Licensing Department
as required by the Paperwork Reduction Act of 1980, PL 96-51
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Gentlemen:
,I
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;  Thank you for your letter. dated May 9,1986, informing us of the steps you have taken to correct the ' items'which we brought to your attention in our
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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 corrective actions will be verified during a future inspection.
Sincerely, hb .f
          ' 'b k D. F. Kirsch, Director Division of Reactor Safety and Projects


Your cooperation with us is appreciated.
===Enclosure:===
A. Notice of Violation


i i
REGION V
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%# ,d g  1450 MARIA LANE. SUITE 210 WALNUT CREEK, CALIFoRNI A 94596
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    '
APR 2 198s Docket Nos. 50-206 50-361 50-362 Southern California Edison Company 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Attention: Mr. Kenneth P. Baskin, Vice President Nuclear Engineering, Safety and Licensing Department Gentlemen:
Subject: NRC Enforcement Actions Related to Inspection Nos. 50-206/85-30; 50-361/85-29; and 50-362/85-28 A team inspection was conducted by Mr. R. C. Wilson and other NRC representatives on September 23-27, 1985, at the San Onofre Nuclear Generating Station of activities authorized by NRC License Nos. DPR-13, NPF-10 and NPF-15. The team's findings were discussed with you and members of your staff at the conclusion of the inspection and documented in Inspection Report Nos. 50-206/85-30, 50-361/85-29, and 50-362/85-2 The inspection included reviews of your implementation of a program required by 10 CFR 50.49 for establishing and maintaining the qualification of electric equipment within the scope of 10 CFR 50./9. The inspection also included evaluation of your actions concerning EQ-related operating license conditions for Units 2 and Based on the results of the inspection, it appears that certain of your activities were not conducted in full compliance with NRC requirements, as set forth in the Notice of Violation, enclosed herewith as Appendix Your response to this Notice is to be submitted in accordance with the provisions of 10 CFR 2.201 as stated in Appendix A, Notice of Violatio In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosure will be placed in the NRC Public Document Roo Should you have any questions concerning this Notice, we will be glad to discuss them with yo '


Sincerely,
s'
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Orlpinoi signe'd b'y
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;      D. 'F."KEfifdh, Director
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;
Division of Reactor Safety and Projects Enclosure:
}  As stated bec w/ enclosure & cy ltr dtd 5/9/86:
;  RSB/ Document Control Desk (RIDS)
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Project Inspector
. Resident Inspector i  G. Cook B. Faulkenberry J. Martin
! State of California
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. Region V b
PJohnson/ norma  AEC affee  DFKirsch
  /86  /86  86


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APR 2 1986 Southern California Edison Company 2
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8606240096 860618 PDR ADOCK 05000206      TCO j* L U f[
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G  PDR
The responses directed by this letter and the accompanying Notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-51
  -- . - - . . - . .- - ._ - -. - - - -  , - . . . . , , . . _ _ . - - , . . -
 
Sincerely, h '
k D. F. Kirsch, Director Division of Reactor Safety and Projects Enclosure:
! A. Notice of Violation
'
i cc w/ enclosure:
i D. J. Fogarty, Executive Vice President, Nuclear Engineering & Operations H. B. Ray, Vice President and Site Manager (San Clemente)
H. E. Morgan, Station Manager (San Clemente)
State of CA (Gordon K. Van Vleck)
 
i


      . ___ _____ -_ _ _ _ _ _ _ _ _ _
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oI 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 close 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 response,      i 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 supplie 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 I . 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. IN 84-44 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 50.4 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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,l-2-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 manne . 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 responsiv . 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 radiatio 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 condition 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 acceptabl . Rockbestos Firewall III cable - This violation is similar to item 2 abov It differs in that additional test data were subsequently obtained from Rockbestos, rather than from another licensee. The same comments appl l l
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Latest revision as of 11:04, 12 December 2020

Discusses Insp Repts 50-206/85-30,50-361/85-29 & 50-362/85-28 on 850923-27 & Forwards Notice of Violation
ML20205M661
Person / Time
Site: San Onofre  Southern California Edison icon.png
Issue date: 04/02/1986
From: Kirsch D
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To: Baskin K
SOUTHERN CALIFORNIA EDISON CO.
Shared Package
ML20205M665 List:
References
NUDOCS 8604150341
Download: ML20205M661 (6)
v • d • e


Text

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APR 2 1986 Docket Nos. 50-206 50-361 50-362 Southern California Edison Company 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Attention: Mr. Kenneth P. Baskin, Vice President Nuclear Engineering, Safety and Licensing Department Gentlemen:

Subject: NRC Enforcement Actions Related to Inspection Nos. 50-206/85-30; 50-361/85-29; and 50-362/85-28 A team inspection was conducted by Mr. R. C. Wilson and other NRC representatives on September 23-27, 1985, at the San Onofre Nuclear Generating Station of activities authorized by NRC License Nos. DPR-13, NPF-10 and NPF-15. The team's findings were discussed with you and members of your staff at the conclusion of the inspection and documented in Inspection Report Nos. 50-206/85-30, 50-361/85-29, and 50-362/85-2 The inspection included reviews of your implementation of a program required by 10 CFR 50.49 for establishing and maintaining.the qualification of electric equipment within the scope of 10 CFR 50.49. 'The inspection aise included evaluation of your actions concerning EQ-related operating license conditions for Units 2 and Based on the results of the inspection, it appears that certain of your activities were not conducted in full compliance with NRC requirements, as set forth in the Notice of Violation, enclosed herewith as Appendix Your response to this Notice is to be submitted in accordance with the provisions of 10 CFR 2.201 as stated in Appendix A, Notice of Violatio ,

In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosure will be placed in the NRC Public Document Roo Should you have any questions concerning this Notice, we will be glad to discuss them with yo PDR G

ADOCK 05000206 PDR h

.

'

.e '

,,-. J

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APR'2 1986 SouthernCaliforniaEdisonCompany.' 2

. i . ~,

The responses-directed by this letter and.'the accom'panying Notice are not subject to the clearance procedures of the': Office of Management and Budget'-

~

as required by the Paperwork Reduction Act of 1980, PL 96-51 ;

Sincerely,

.

'

,

'

~ >

, ,-

Fa D. F. Kirsch, Director Division of Reactor Safety and Projects l

Enclosure:

,

A. Notice of Violation

REGION V S & 1450 MARlA LANE,SulTE 210 U WALNUT CREEK, CAllFORNI A 94596

%.'....o -

APR 2 19 i6 Docket Nos. 50-206 50-361 50-362 Southern California Edison Company 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Attention: Mr. Kenneth P. Baskin, Vice President Nuclear Engineering, Safety and Licensing Department Gentlemen:

Subject: NRC Enforcement Actions Related to Inspection Nos. 50-206/85-30; 50-361/85-29; and 50-362/85-28 A team inspection was conducted by Mr. R. C. Wilson and other NRC representatives on September 23-27, 1985, at the San Onofre Nuclear Generating Station of activities authorized by NRC License Nos. DPR-13, NPF-10 and NPF-15. The team's findings were discussed with you and members of your staff at the conclusion of the inspection and documented in Inspection Report Nos. 50-206/85-30, 50-361/85-29, and 50-362/85-2 The inspection included reviews of your implementation of a program required by 10 CFR 50.49 for establishing and maintaining the qualification of electric equipment within the scope of 10 CFR 50.49. The inspection also included evaluation of your actions concerning EQ-related operating license conditions for Units 2 and Based on the results of the inspection, it appears that certain of your activities were not conducted in full compliance with NRC requirements, as

set forth in the Notice of Violation, enclosed herewith as Appendix Your response to this Notice is to be submitted in accordance with the provisions of 10 CFR 2.201 as stated in Appendix A, Notice of Violatio In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosure will be placed in the NRC Public Document Roo Should you have any questions concerning this Notice, we will be glad to discuss them with yo _ - - _ - _ _ _ _ _ _ _ _ _ _ _ . _ _ - _ _ _ - -. _ _ _ _ - - - - - . _ _ - _ _ _ _ _ _ __- _ --___-___ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ - - _ _ _ _

_ _ ._ __

..

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.

., ,

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,

.

APR 2 1986 Southern California Edison Company 2

- -

r-The responses directed by this letter and the accompanying Notice are not

.; subject to the clearance procedures of the Office of Management and Budget .

as required by the Paperwork Reduction Act of 1980, PL 96-51

Sincerely, hb .f

' 'b k D. F. Kirsch, Director Division of Reactor Safety and Projects

Enclosure:

A. Notice of Violation

REGION V

  • s

%# ,d g 1450 MARIA LANE. SUITE 210 WALNUT CREEK, CALIFoRNI A 94596

..... -

'

APR 2 198s Docket Nos. 50-206 50-361 50-362 Southern California Edison Company 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Attention: Mr. Kenneth P. Baskin, Vice President Nuclear Engineering, Safety and Licensing Department Gentlemen:

Subject: NRC Enforcement Actions Related to Inspection Nos. 50-206/85-30; 50-361/85-29; and 50-362/85-28 A team inspection was conducted by Mr. R. C. Wilson and other NRC representatives on September 23-27, 1985, at the San Onofre Nuclear Generating Station of activities authorized by NRC License Nos. DPR-13, NPF-10 and NPF-15. The team's findings were discussed with you and members of your staff at the conclusion of the inspection and documented in Inspection Report Nos. 50-206/85-30, 50-361/85-29, and 50-362/85-2 The inspection included reviews of your implementation of a program required by 10 CFR 50.49 for establishing and maintaining the qualification of electric equipment within the scope of 10 CFR 50./9. The inspection also included evaluation of your actions concerning EQ-related operating license conditions for Units 2 and Based on the results of the inspection, it appears that certain of your activities were not conducted in full compliance with NRC requirements, as set forth in the Notice of Violation, enclosed herewith as Appendix Your response to this Notice is to be submitted in accordance with the provisions of 10 CFR 2.201 as stated in Appendix A, Notice of Violatio In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosure will be placed in the NRC Public Document Roo Should you have any questions concerning this Notice, we will be glad to discuss them with yo '

s'

.

.

., .>

,

,

APR 2 1986 Southern California Edison Company 2

'

-

The responses directed by this letter and the accompanying Notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-51

Sincerely, h '

k D. F. Kirsch, Director Division of Reactor Safety and Projects Enclosure:

! A. Notice of Violation

'

i cc w/ enclosure:

i D. J. Fogarty, Executive Vice President, Nuclear Engineering & Operations H. B. Ray, Vice President and Site Manager (San Clemente)

H. E. Morgan, Station Manager (San Clemente)

State of CA (Gordon K. Van Vleck)

i

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