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MONTHYEARML20199E8271986-05-0909 May 1986 Responds to NRC Re Violations Noted in Insp Repts 50-206/85-30,50-361/85-29 & 50-362/85-28.Corrective Actions: Environ Qualification Packages Will Be Revised to Include Addl Mfg Info Re Galite & Prestolite Processes Project stage: Other ML20197H5401986-05-0909 May 1986 Responds to NRC Re Violations Noted in Insp Repts 50-206/85-30,50-361/85-29 & 50-362/85-28.Corrective Actions: Environ Qualification Document Packages Revised Re Cable Insulation,Solenoid Valves & Honeywell Transducers Project stage: Other 1986-05-09
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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217P7111999-10-26026 October 1999 Informs That Licensee 990330 Response to GL 97-06 Provides Reasonable Assurance That Condition of Licensee Steam Generator Internals Is in Compliance with Current Licensing Bases for Plant ML20217K3571999-10-21021 October 1999 Discusses Use of SONGS as Generic Safety Issue 191 Ref Plant.Future Requests for Info & Addl Coordination Activities Be Handled Through D Evans of Organization.With Diskette ML20217K8541999-10-21021 October 1999 Forwards Revised Pages to ERDS Data Point Library,Per Requirements of 10CFR50,App E,Section VI.3.a.Described Unit 2 & 3 Changes for 2/3R7813 Were Completed on 990924 ML20217L9491999-10-21021 October 1999 Forwards SONGS Emergency Response Telephone Directory, for Oct-Dec 1999 ML20217J8631999-10-15015 October 1999 Forwards Insp Repts 50-361/99-12 & 50-362/99-12 on 990808- 0918.One Violation Identified Involving Inoperability of Emergency Diesel Generator in Excess of Allowed Outage Time ML20217E3221999-10-13013 October 1999 Forwards MORs for Sept 1999 for Songs,Units 2 & 3.No Challenges Were Noted to Psvs for Either Units 2 or 3 ML20217E7671999-10-12012 October 1999 Forwards Rev 62 to NRC Approved Aug 1983, Physical Security Plan,Songs,Units 1,2 & 3, IAW 10CFR50.54(p).Changes,as Described in Encls 1 & 2,do Not Reduce Effectiveness of Plan.Encl Withheld,Per 10CFR73.21 ML20217B5981999-10-0606 October 1999 Informs That Staff Concluded That All Requested Info for GL 98-01, Year 2000 Readiness in Us Nuclear Power Plants, Provided for San Onofre Nuclear Generating Station,Units 2 & 3 ML20216H8741999-09-29029 September 1999 Provides Requested Written Response to GL 99-02, Lab Testing of Nuclear-Grade Activated Charcoal. Lab Testing of Charcoal Adsorber Samples for Creacus & Pacu Satisfies Listed Requirements ML20216H8541999-09-29029 September 1999 Submits Encl Request for Relief from ASME Code,Section III Requirements in 10CFR50.55(a)(3) to Use Mechanical Nozzle Seal Assembly as Alternate ASME Code Replacement at SONGS, Units 2 & 3 for Period of Operation Beginning with Cycle 11 ML20216J2631999-09-28028 September 1999 Forwards Copy of Final Accident Sequence Precursor (ASP) Analysis of Operational Event at Songs,Unit 2,reported in LER 361/98-003 ML20212H4461999-09-28028 September 1999 Forwards Suppl Info,As Discussed with NRC During 990812 Telcon,To Support Risk Informed Inservice Testing & GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Movs ML20212G5611999-09-24024 September 1999 Informs NRC That SCE Remains Committed to Performing Eddy Current Examinations of 100% of Reactor Vessel Head Penetrations at Songs,Unit 3.Exams Will Not Be Performed During Cycle 11 RFO 05000361/LER-1999-005, Forwards 30-day follow-up LER 99-005-00,describing Loss of Physical Train Separation in Control Room.Any Actions Listed Intended to Ensure Continued Compliance with Existing Commitments1999-09-23023 September 1999 Forwards 30-day follow-up LER 99-005-00,describing Loss of Physical Train Separation in Control Room.Any Actions Listed Intended to Ensure Continued Compliance with Existing Commitments ML20212D9921999-09-16016 September 1999 Informs That on 990818,NRC Staff Completed Midcycle PPR of San Onofre.Nrc Plan to Conduct Core Insps & One Safety Issues Evaluation of MOVs at Facility Over Next 7 Months. Details of Insp Plan Through March 2000 Encl ML20212A4061999-09-14014 September 1999 Forwards Revised Pages to ERDS Data Point Library.Described Unit 2 Changes for 2R7817 & 2R7828 Were Completed on 990818 & Unit 3 Change for 3R7828 Was Completed on 990903 ML20216E6031999-09-10010 September 1999 Provides Response to NRC Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Exams, Dtd 990820.Schedule Shown on Attachment 1, Operator Licensing Exam Data, Provides Util Best Estimate Through Cy 2003 ML20217B9011999-09-10010 September 1999 Responds to Which Addressed Concerns Re Y2K Issue & Stockpiling of Potassium Iodide (Ki) Tablets by Informing That San Onofre Nuclear Station Already Completed All Work Required to Be Ready for Y2K Transition ML20211K4191999-09-0303 September 1999 Final Response to FOIA Request for Documents.Documents Listed in App a Being Withheld in Part (Ref FOIA Exemptions 5 & 7) ML20211N0261999-09-0303 September 1999 Forwards Exemption from Certain Requirements of 10CFR50.44 & 10CFR50,app A,General Design Criterion 41 in Response to Util Request of 980910,as Supplemented 990719 & SER 05000206/LER-1999-001, Forwards LER 99-001-00 for Occurrence Re Unattended Security Weapon Inside Protected Area.Single Rept for Unit 1 Is Being Submitted,Iaw NUREG-1022,Rev 1,since Condition Involves Shared Sys & Is Applicable to Units 1,2 & 31999-08-31031 August 1999 Forwards LER 99-001-00 for Occurrence Re Unattended Security Weapon Inside Protected Area.Single Rept for Unit 1 Is Being Submitted,Iaw NUREG-1022,Rev 1,since Condition Involves Shared Sys & Is Applicable to Units 1,2 & 3 ML20211H3321999-08-30030 August 1999 Discusses 1999 Emergency Preparedness Exercise Extent of Play & Objectives.Based on Review,Nrc Has Determined That Exercise Extent of Play & Objectives Are Appropriate to Meet Emergency Plan Requirements ML20211J7151999-08-27027 August 1999 Forwards Insp Repts 50-361/99-09 & 50-362/99-09 on 990627- 0807.Two Violations Being Treated as non-cited Violations ML20211H8561999-08-23023 August 1999 Forwards SE Accepting Licensee 970625 Requests for Relief RR-E-2-03 - RR-E-2-04 from Exam Requirements of Applicable ASME Code,Section Xi,For First Containment ISI Interval ML20211J5821999-08-23023 August 1999 Corrected Copy of ,Changing Application Date from 970625 to 990625.Ltr Forwarded SE Accepting Licensee 990625 Requests for Relief RR-E-2-03 - RR-E-2-08 from Exam Requirements of Applicable ASME Code,Section XI as Listed ML20210V4271999-08-16016 August 1999 Forwards Proprietary Certified Renewal Applications for SROs a Harkness,R Grabo & T Vogt & RO D Carter,Submitted on Facsimile Form NRC-398 & Certified NRC Form 396.Encls Withheld ML20210R6681999-08-13013 August 1999 Forwards Response to NRC RAI Re SCE License Amend Applications 173 & 159 for Songs,Units 2 & 3,proposed Change Number 485,which Requests Addition of SR to TS 3.3.9, CR Isolation Signal ML20211A9501999-08-12012 August 1999 Discusses 990720-21 Workshop Conducted in Region IV Ofc,Re Exchange of Info in Area of Use of Risk Insights in Regulatory Activities.List of Attendees,Summary of Topic & Issues,Agenda & Copies of Handouts Encl ML20210Q6451999-08-12012 August 1999 Forwards Monthly Operating Repts for July 1999 for SONGS, Units 2 & 3,per TS 5.7.1.4.There Were No Challenges to Pressurizer Safety Valves for Either Units ML20210P5711999-08-11011 August 1999 Forwards Amend Application Number 189 for License NPF-10 & Amend Application Number 174 to License NPF-15,replacing Analytical Limits Currently Specified as Acceptance Criteria with Allowable Values,Per Encl Calculation E4C-098 ML20210P4681999-08-11011 August 1999 Forwards COLR for Cycle 10 for Songs,Units 2 & 3,IAW TS Section 5.7.1.5.d, Colr. Changes to COLR Parameters Have Been Conducted IAW Approved COLR Methodologies & All Applicable Limits of Safety Analysis Were Met ML20210P6221999-08-10010 August 1999 Forwards Replacement Pages for Attachments E & F of Amend Application Numbers 168 & 154 for Songs,Units 2 & 3.Pages Are Provided to Correct Errors to Pagination & Headings in 970618 Submittal ML20210N9721999-08-10010 August 1999 Responds to Appeal of FOIA Request for Documents Re Osre Issue.No Osre Visit Scheduled for Sept 1996 at Plant,Per 990722 Telcon.V Dricks,In Ofc of Public Affairs Should Be Contacted Re Osre Issue ML20210N0901999-08-0909 August 1999 Informs That 990312 Application Requested Amends to Licenses DPR-13,NPF-10 & NPF-15,respectively,being Treated as Withdrawn.Proposed Change Would Have Modified Facility TSs Pertaining to SONGS Physical Security Plan ML20210N5051999-08-0909 August 1999 Forwards Cycle 10 Update to TS Bases,Which Have Been Revised Between 980101-990630,per 10CFR50.71(e) 05000361/LER-1999-004, Forwards LER 99-004-00 Re Automatic Tgis Actuation.Event Affected Units 2 & 3 Equally Because Tgis Is Shared Sys. Single Rept Is Being Provided for Unit 2 IAW NUREG-1022, Rev 1.No New Commitments Are Contained in Encl1999-08-0606 August 1999 Forwards LER 99-004-00 Re Automatic Tgis Actuation.Event Affected Units 2 & 3 Equally Because Tgis Is Shared Sys. Single Rept Is Being Provided for Unit 2 IAW NUREG-1022, Rev 1.No New Commitments Are Contained in Encl ML20210L2311999-08-0505 August 1999 Forwards ISI Summary Rept,Including Owners Repts of Repairs & Replacements,For Songs,Unit 3.Rept Covers 970916 Through 990509,date Unit 3 Returned to Service Following Cycle 10 Refueling Outage ML20210L1461999-08-0303 August 1999 Informs That NRC Plans to Administer Gfes of Written Operator Licensing Exam on 991006.Requests Submittal of Ltr Identifying Individuals Taking Exam,Personnel Allowed Access to Exams & Mailing Address for Exams ML20216D9671999-07-29029 July 1999 Provides Response to RAI to Support Proposed TS Change 460 Re Containment Isolation Valve Completion Time for SONGS, Units 2 & 3.Rev 3 to Abnormal Operating Instruction SO23-13-14, Reactor Coolant Leak, Encl ML20210C1821999-07-22022 July 1999 Forwards Rept Providing Results of Insp of Eggcrate Tube Supports Done on Secondary Side of Sgs,Using Remote Controlled Visual Equipment ML20210B2451999-07-21021 July 1999 Forwards Response to NRC 990615 RAI Re GL 95-07, Pressure Locking & Thermal Bldg of SR Power-Operated Gate Valves, for Songs,Units 2 & 3 ML20210B9891999-07-20020 July 1999 Ack Receipt of Transmitting Plant Emergency Plan Implementing Procedure SO123-VIII-1, Recognition & Classification of Emergencies ML20209J5241999-07-19019 July 1999 Provides Clarification of Util Intentions Re Disposition of Systems for Which Exemption & TS Changes Were Requested in Licensee .Deferment of Action Re Hydrogen Monitors,Encl ML20210N2881999-07-19019 July 1999 Forwards Rev 61 to Physical Security Plan,Rev 21 to Safeguards Contingency Plan & Rev 20 to Security Force Training & Qualification Plan,Per 10CFR50.54(p),for Plant. Screening Criteria Forms Encl.Plans Withheld ML20210A2911999-07-19019 July 1999 Submits Withdrawal Request Submitted by Ltr Dtd 990312, Requesting NRC Approval of Revs to Physical Security Plan & Safeguards Contingency Plan Tactical Response Plan ML20209G3421999-07-15015 July 1999 Forwards Table of 16 Affected Tube Locations in SG E089, Discovered During Cycle 10 Outage Insp,Which Were Probably Not Examined by Bobbin During Cycle Outage Insp ML20209D8051999-07-12012 July 1999 Discusses Licensee Response to RAI Re GL 92-01,Rev 1,Suppl 1, Rc Structural Integrity, Issue on 950519 to Plant. NRC Revised Info in Reactor Vessel Integrity Database & Is Releasing It as Rvid Version 2 ML20209F5681999-07-0909 July 1999 Forwards Insp Repts 50-361/99-08 & 50-362/99-08 on 990516- 0626.One Violation Identified & Being Treated as Noncited Violation,Consistent with App C of Enforcement Policy ML20209C1571999-07-0202 July 1999 Forwards Response to NRC RAI Re SCE Submittal Dtd 980710,re GL 96-06, Assurance of Equipment Operability & Containment Integrity During Design-Basis Accident Conditions ML20196K6721999-07-0202 July 1999 Discusses 990628 Meeting Conducted in Region IV Office Re Status of San Onofre Nuclear Generating Station Emergency Preparedness Program.List of Attendees & Licensee Presentation Encl 1999-09-03
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML20217L9491999-10-21021 October 1999 Forwards SONGS Emergency Response Telephone Directory, for Oct-Dec 1999 ML20217K3571999-10-21021 October 1999 Discusses Use of SONGS as Generic Safety Issue 191 Ref Plant.Future Requests for Info & Addl Coordination Activities Be Handled Through D Evans of Organization.With Diskette ML20217K8541999-10-21021 October 1999 Forwards Revised Pages to ERDS Data Point Library,Per Requirements of 10CFR50,App E,Section VI.3.a.Described Unit 2 & 3 Changes for 2/3R7813 Were Completed on 990924 ML20217E3221999-10-13013 October 1999 Forwards MORs for Sept 1999 for Songs,Units 2 & 3.No Challenges Were Noted to Psvs for Either Units 2 or 3 ML20217E7671999-10-12012 October 1999 Forwards Rev 62 to NRC Approved Aug 1983, Physical Security Plan,Songs,Units 1,2 & 3, IAW 10CFR50.54(p).Changes,as Described in Encls 1 & 2,do Not Reduce Effectiveness of Plan.Encl Withheld,Per 10CFR73.21 ML20216H8741999-09-29029 September 1999 Provides Requested Written Response to GL 99-02, Lab Testing of Nuclear-Grade Activated Charcoal. Lab Testing of Charcoal Adsorber Samples for Creacus & Pacu Satisfies Listed Requirements ML20216H8541999-09-29029 September 1999 Submits Encl Request for Relief from ASME Code,Section III Requirements in 10CFR50.55(a)(3) to Use Mechanical Nozzle Seal Assembly as Alternate ASME Code Replacement at SONGS, Units 2 & 3 for Period of Operation Beginning with Cycle 11 ML20212H4461999-09-28028 September 1999 Forwards Suppl Info,As Discussed with NRC During 990812 Telcon,To Support Risk Informed Inservice Testing & GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Movs ML20212G5611999-09-24024 September 1999 Informs NRC That SCE Remains Committed to Performing Eddy Current Examinations of 100% of Reactor Vessel Head Penetrations at Songs,Unit 3.Exams Will Not Be Performed During Cycle 11 RFO 05000361/LER-1999-005, Forwards 30-day follow-up LER 99-005-00,describing Loss of Physical Train Separation in Control Room.Any Actions Listed Intended to Ensure Continued Compliance with Existing Commitments1999-09-23023 September 1999 Forwards 30-day follow-up LER 99-005-00,describing Loss of Physical Train Separation in Control Room.Any Actions Listed Intended to Ensure Continued Compliance with Existing Commitments ML20212A4061999-09-14014 September 1999 Forwards Revised Pages to ERDS Data Point Library.Described Unit 2 Changes for 2R7817 & 2R7828 Were Completed on 990818 & Unit 3 Change for 3R7828 Was Completed on 990903 ML20216E6031999-09-10010 September 1999 Provides Response to NRC Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Exams, Dtd 990820.Schedule Shown on Attachment 1, Operator Licensing Exam Data, Provides Util Best Estimate Through Cy 2003 05000206/LER-1999-001, Forwards LER 99-001-00 for Occurrence Re Unattended Security Weapon Inside Protected Area.Single Rept for Unit 1 Is Being Submitted,Iaw NUREG-1022,Rev 1,since Condition Involves Shared Sys & Is Applicable to Units 1,2 & 31999-08-31031 August 1999 Forwards LER 99-001-00 for Occurrence Re Unattended Security Weapon Inside Protected Area.Single Rept for Unit 1 Is Being Submitted,Iaw NUREG-1022,Rev 1,since Condition Involves Shared Sys & Is Applicable to Units 1,2 & 3 ML20210V4271999-08-16016 August 1999 Forwards Proprietary Certified Renewal Applications for SROs a Harkness,R Grabo & T Vogt & RO D Carter,Submitted on Facsimile Form NRC-398 & Certified NRC Form 396.Encls Withheld ML20210R6681999-08-13013 August 1999 Forwards Response to NRC RAI Re SCE License Amend Applications 173 & 159 for Songs,Units 2 & 3,proposed Change Number 485,which Requests Addition of SR to TS 3.3.9, CR Isolation Signal ML20210Q6451999-08-12012 August 1999 Forwards Monthly Operating Repts for July 1999 for SONGS, Units 2 & 3,per TS 5.7.1.4.There Were No Challenges to Pressurizer Safety Valves for Either Units ML20210P5711999-08-11011 August 1999 Forwards Amend Application Number 189 for License NPF-10 & Amend Application Number 174 to License NPF-15,replacing Analytical Limits Currently Specified as Acceptance Criteria with Allowable Values,Per Encl Calculation E4C-098 ML20210P4681999-08-11011 August 1999 Forwards COLR for Cycle 10 for Songs,Units 2 & 3,IAW TS Section 5.7.1.5.d, Colr. Changes to COLR Parameters Have Been Conducted IAW Approved COLR Methodologies & All Applicable Limits of Safety Analysis Were Met ML20210P6221999-08-10010 August 1999 Forwards Replacement Pages for Attachments E & F of Amend Application Numbers 168 & 154 for Songs,Units 2 & 3.Pages Are Provided to Correct Errors to Pagination & Headings in 970618 Submittal ML20210N5051999-08-0909 August 1999 Forwards Cycle 10 Update to TS Bases,Which Have Been Revised Between 980101-990630,per 10CFR50.71(e) 05000361/LER-1999-004, Forwards LER 99-004-00 Re Automatic Tgis Actuation.Event Affected Units 2 & 3 Equally Because Tgis Is Shared Sys. Single Rept Is Being Provided for Unit 2 IAW NUREG-1022, Rev 1.No New Commitments Are Contained in Encl1999-08-0606 August 1999 Forwards LER 99-004-00 Re Automatic Tgis Actuation.Event Affected Units 2 & 3 Equally Because Tgis Is Shared Sys. Single Rept Is Being Provided for Unit 2 IAW NUREG-1022, Rev 1.No New Commitments Are Contained in Encl ML20210L2311999-08-0505 August 1999 Forwards ISI Summary Rept,Including Owners Repts of Repairs & Replacements,For Songs,Unit 3.Rept Covers 970916 Through 990509,date Unit 3 Returned to Service Following Cycle 10 Refueling Outage ML20216D9671999-07-29029 July 1999 Provides Response to RAI to Support Proposed TS Change 460 Re Containment Isolation Valve Completion Time for SONGS, Units 2 & 3.Rev 3 to Abnormal Operating Instruction SO23-13-14, Reactor Coolant Leak, Encl ML20210C1821999-07-22022 July 1999 Forwards Rept Providing Results of Insp of Eggcrate Tube Supports Done on Secondary Side of Sgs,Using Remote Controlled Visual Equipment ML20210B2451999-07-21021 July 1999 Forwards Response to NRC 990615 RAI Re GL 95-07, Pressure Locking & Thermal Bldg of SR Power-Operated Gate Valves, for Songs,Units 2 & 3 ML20210A2911999-07-19019 July 1999 Submits Withdrawal Request Submitted by Ltr Dtd 990312, Requesting NRC Approval of Revs to Physical Security Plan & Safeguards Contingency Plan Tactical Response Plan ML20210N2881999-07-19019 July 1999 Forwards Rev 61 to Physical Security Plan,Rev 21 to Safeguards Contingency Plan & Rev 20 to Security Force Training & Qualification Plan,Per 10CFR50.54(p),for Plant. Screening Criteria Forms Encl.Plans Withheld ML20209J5241999-07-19019 July 1999 Provides Clarification of Util Intentions Re Disposition of Systems for Which Exemption & TS Changes Were Requested in Licensee .Deferment of Action Re Hydrogen Monitors,Encl ML20209G3421999-07-15015 July 1999 Forwards Table of 16 Affected Tube Locations in SG E089, Discovered During Cycle 10 Outage Insp,Which Were Probably Not Examined by Bobbin During Cycle Outage Insp ML20209C1571999-07-0202 July 1999 Forwards Response to NRC RAI Re SCE Submittal Dtd 980710,re GL 96-06, Assurance of Equipment Operability & Containment Integrity During Design-Basis Accident Conditions ML20210N9871999-07-0101 July 1999 Appeals Denial of Documents Re Sept 1996 Osre for San Onofre Nuclear Generating Station.Requests Copies of Sept 1996 Osre Rept & Any More Recent Osre Repts ML20209B3571999-06-28028 June 1999 Submits Response to GL 98-01,Suppl 1 Y2K Readiness of Computer Sys at Nuclear Power Plants. GL 98-01 Requested Response on Status of Facility Y2K Readiness by 990701. Disclosure Encl ML20209B4831999-06-25025 June 1999 Requests NRC Approval of Six Relief Requests from ASME Code Requirement for Containment ISI Exams.Six Relief Requests, Provided as Enclosures 1-6,are as Listed ML20196A9801999-06-17017 June 1999 Responds to NRC 990420 RAI Re Proposed risk-informed Inservice Testing & GL 96-05 Programs at Songs,Units 2 & 3. Revised Pages to risk-informed Inservice Testing Program, Encl ML20195G8091999-06-14014 June 1999 Forwards Response to RAI Made During 990511 Telcon Re LARs 184 & 170 for SONGS Units 2 & 3.Amend Applications Proposed Restriction on Operation with Channel of RAS or Efas in Tripped Condition ML20195K4201999-06-11011 June 1999 Forwards LERs 99-003-00 & 99-004-00 Re Manual Esfas (Reactor Trips) Due to Problems with Main Feedwater Control.Two Events Are Being Reported Separately Because Actual Causes Are Considered Different & Independent of Each Other ML20195H1561999-06-10010 June 1999 Forwards MORs for May 1999 for Songs,Units 2 & 3.There Were No Challenges to Pressurizer Safety Valves for Either Unit 2 & 3 ML20195E4981999-06-0808 June 1999 Forwards Application for Amends 188 & 173 to Licenses NPF-10 & NPF-15 for SONGS Units 2 & 3,respectively.Amends Would Revise TS 3.5.2,3.1.9,3.7.1 & 5.1.7.5 Re Small Break LOCA Charging Flow & Main Steam Safety Valve Setpoints ML20196L3191999-05-24024 May 1999 Forwards ISI Summary Rept,Including Owners Repts of Repairs & Replacements for Songs,Unit 2.Rept Covers Period of 970916-990226 ML20207A3831999-05-24024 May 1999 Responds to NRC 990326 RAI on DG Srs.Proposed to Add Listed Sentence to TS Bases for SRs 3.8.1.7,3.8.1.12 & 3.8.1.15,as Result of Discussion with NRC During 990427 Telcon ML20211K4261999-05-18018 May 1999 FOIA Request for Documents Re San Onofre OI Repts 4-98-041, 4-98-043 & 4-98-045 ML20206S7161999-05-17017 May 1999 Forwards MORs for Apr 1999 for Songs,Units 2 & 3.There Were No Challenges to Pressurizer Safety Valves for Either Unit 2 or 3 ML20206N4711999-05-13013 May 1999 Provides Info Requested by NRC Re Reduced Pressurizer Water Vol Change Amends Application 172 & 158 for Songs,Units 2 & 3,respectively.Proposed Change Will Reduce Pressurizer Water Level Required for Operability ML20206M7791999-05-13013 May 1999 Informs NRC of Changes Being Made to Emergency Response Data Sys (ERDS) at SONGS Unit 3.Revised Page to ERDS Data Point Library Is Provided in Encl ML20206K6891999-05-11011 May 1999 Forwards Approved Amends to NPDES Permits CA0108073,Order 94-49 & CA0108181,Order 94-50 & State Water Resources Board Resolution ML20206M0681999-05-10010 May 1999 Submits Correction to Info Contained in Licensee to NRC Re Proposed TS Change Number NPF-10/15-475.Stated Info Was Incorrect in That Overtime Provisions Were Not Contained in TR at Time of Was Submitted ML20206H0451999-05-0404 May 1999 Forwards Annual Financial Repts for Listed Licensees of Songs,Units 1,2 & 3.Each Rept Includes Appropriate Certified Financial Statement Required by 10CFR50.71(b) ML20206H1931999-05-0303 May 1999 Forwards 1998 Annual Rept, for SONGS Units 2 & 3 & PVNGS Units 1,2 & 3.SCEs Form 10K Annual Rept to Securites & Exchange Commission for Fiscal Yr Ending 981231,encl ML20206C5151999-04-29029 April 1999 Forwards 1998 Radiological Environ Operating Rept for Songs,Units 1,2 & 3. Annual Radiological Environ Operating Rept Covers Operation of Songs,Units 1,2 & 3 During CY98 & Includes Summaries Interpretations & Analysis of Trends ML20206E5851999-04-29029 April 1999 Forwards Annual Radioactive Effluent Release Rept for 1998 for SONGS Units 1,2 & 3. Also Encl Are Rev 13 to Unit 1 ODCM & Rev 31 to Units 2 & 3 Odcm 1999-09-29
[Table view] Category:UTILITY TO NRC
MONTHYEARML20059C1071990-08-24024 August 1990 Forwards Addenda 10-1A,10-1B & 10-1C to Physical Security Plan.Encls Withheld (Ref 10CFR73.21) ML20059E6951990-08-24024 August 1990 Forwards Rev 30 to Physical Security Plan.Rev Withheld (Ref 10CFR73.21) ML20059B8861990-08-22022 August 1990 Advises That Dl Hill Employment W/Util Terminated,Effective 900817.Operator License OP-50333 Expired ML13302B3411990-08-21021 August 1990 Responds to NRC Bulletin 88-010 Re Nonconforming molded-case Circuit Breakers (Mccbs).Affected MCCBs Purchased for Use in safety-related Applications,Including MCCBs Used W/Motor Controllers.Outage Rept Encl,Per 890330 Ltr ML20064A2161990-08-16016 August 1990 Responds to NRC Re Violations Noted in Insp Repts 50-361/90-16 & 50-362/90-16.Reply to Notice of Violation Not Required Due to Sufficient Info Provided in ,Per 900807 Discussion W/R Huey ML13309A9211990-08-14014 August 1990 Forwards Monthly Operating Repts for Jul 1990 for San Onofre Units 2 & 3,revised Unit 2 Monthly Operating Rept for June 1990 & Rev 22 to ODCM ML20058Q2961990-08-14014 August 1990 Forwards Util & June 1990 NPDES Monitoring Rept. W/O Rept ML20058N0371990-08-0909 August 1990 Advises That on 900713,new Land Use Located W/Calculated Dose Greater than Value Currently Calculated.New Location Results in Annual Dose Increase of 27% for Units 2 & 3 & 39% Increase for Unit 1 ML20056A1781990-08-0202 August 1990 Discusses Review of Possibility of Accelerating Schedule for Performing & Submitting Results of Individual Plant Exams for Units 1,2 & 3.Util Believes That Submittal Schedule for Unit 1 Can Be Accelerated to 920102 ML18041A2221990-07-31031 July 1990 Responds to NRC 900518 Ltr Re Violations Noted in Insp Repts 50-206/90-10,50-361/90-10 & 50-362/90-10.Corrective Action: computer-based Mgt Sys Will Be Developed to Permit Incoming Revised Info to Be Matched W/Documents Requiring Review ML20055H9641990-07-27027 July 1990 Responds to NRC Re Violations Noted During Special Safety Sys Functional Insp on 891030-1130.Corrective Action:Util Will Review & Revise Operating & Calibr Procedures by 901031 ML20055H5731990-07-24024 July 1990 Provides Notification of Completion of Installation of Backup Nitrogen Sys Isolation Check Valves & Test Connections at Facility ML20055H2631990-07-23023 July 1990 Discusses Model 3RE-7870 Not Being Declared Operable Due to Lack of Process Flow.Monitor Failed on 900708.Caused by Moisture Intrusion Into Housing.All Affected Components Repaired or Replaced ML20055F1901990-07-0909 July 1990 Informs That Ej Schoonover Employment W/Util Terminated, Effective 900629 ML20044A4121990-06-27027 June 1990 Requests Approval of Use of Plugs Fabricated of nickel-chromiun-iron Uns N-06690 Matl to Plug Tubes in Plant Steam Generators.Change to Use Alloy 690 Tube Plugs Results from Matl Corrosion Consideration ML20056A8841990-06-25025 June 1990 Responds to NRC Forwarding Insp Repts 50-206/90-10,50-361/90-10 & 50-362/90-10.Results of Review of Awareness & Response to Industry Check Valve Concerns & Evaluation of Need to Establish Dedicated Program Provided ML20043H7851990-06-19019 June 1990 Informs That Jl Mullins Employment W/Util Terminated Effective 900608.Operator License OP-50089-2 Expired ML20043H5101990-06-19019 June 1990 Informs That Wk Giffrow Employment W/Util Terminated. Operator License OP-50050-2 Expired ML13304A4861990-06-0404 June 1990 Forwards Evaluation of Unisolable Piping from RCS W/Potential for Leakage Induced Thermal Stresses in Response to NRC Bulletin 88-008 SONGS 2 & 3, in Response to Request ML20043B4911990-05-22022 May 1990 Submits Rept:On 900507,eddy Current Insp of Steam Generator Tubing Completed.Of 2,106 Tubes Inspected in Steam Generator E-088 No Tubes Found Defective.One Tube in Steam Generator E-089 Found Defective & Plugged ML20043B1411990-05-17017 May 1990 Informs That Senior Reactor Operator License No Longer Needed for JW Ryder,Effective 900425.License SOP-50288 Expired on 900425 ML13309A9151990-05-14014 May 1990 Forwards Monthly Operating Repts for Apr 1990 for San Onofre Nuclear Generating Station Units 2 & 3 ML20043A0051990-05-0404 May 1990 Informs of Expiration of WR Seiler Senior Reactor Operator License,Effective 900502 ML20042G6531990-05-0303 May 1990 Forwards Addendum 10-1B to Physical Security Plan.Encl Withheld (Ref 10CFR73.21) ML20042F7101990-05-0202 May 1990 Informs That Gb Swift Transferred to Position Not Requiring Operator License,Effective 900423 & License Expired,Per 10CFR55.55(a) ML20012E8341990-03-29029 March 1990 Advises That Reactor Operator License OP-50072-2 Expired on 900312 & No Longer Needed ML13303B1981990-03-12012 March 1990 Forwards Table Re FSAR Chapter 15 Design Basis Event & Rev 0 to M-89047, Instrument Drift Study San Onofre Nuclear Generating Station Units 2 & 3, in Support of Proposed Change Notices 275 & 280,per NRC Request ML20012B6701990-03-12012 March 1990 Advises That Response to SSFI Repts 50-361/89-200 & 50-362/89-200 Will Be Provided by 900412 Due to Unexpected Diversion of Resources to Address Other Issues Such as Trip of Unit 3 on 900223 & Safety Valve Evaluations ML13304A4591990-03-0707 March 1990 Forwards Rev 0 to M 86420, Spurious Actuation Evaluation Component Cooling Water Sys - Operability Assessment. ML20012B8061990-03-0505 March 1990 Responds to NRC 900205 Ltr Re Violations Noted in Insp Repts 50-361/89-33 & 50-362/89-33.Corrective Actions:Action Taken W/Responsible Supervisor to Ensure That Health Physics Technician Overtime Controlled & Authorized ML13304A4551990-02-16016 February 1990 Forwards Rev 6 to Spent Fuel Pool Reracking Licensing Rept. Encl 1 Lists Summary of Rev 6 Changes & Encl 2 Lists Changes (Insert Pages) to Rev 5 Reracking Licensing Rept ML20006E8801990-02-14014 February 1990 Informs That Dl Daily Employment W/Util Terminated Effective 900209.License SOP-50229-1 Expired ML20006D9661990-02-0707 February 1990 Advises That Listed Individuals No Longer Require Senior Reactor Operator Licenses,Effective on 900117 ML20011E5041990-02-0707 February 1990 Informs of Termination of Rl Sprague Employment W/Util, Effective 900125 ML13303B1871990-01-18018 January 1990 Forwards Rev 5 to Amend Applications 64 & 78 to Licenses NPF-10 & NPF-15,respectively,re Spent Fuel Pool Reracking. New Racks Will Increase Number of Storage Locations in Each Spent Fuel Pool from 800 to 1,542 Elements ML20011F0381990-01-18018 January 1990 Documents Commitment Re Impact of outage-related Overtime, Based on Interview at Site on 900112.Util Will Not Schedule Heavy Use of Overtime for Duration of Refueling Outage for Personnel Addressed by Tech Specs Assigned to Unit ML13303B1791990-01-0808 January 1990 Forwards Amend Applications 70 & 56 to Licenses NPF-10 & NPF-15,respectively,revising Tech Spec 3/4.3.3.5, Remote Shutdown to Increase Interval for Refueling Surveillance Tests to Nominally 24 Months & Max of 30 Months ML13303B1841990-01-0808 January 1990 Forwards Amend Applications 69 & 55 to Licenses NPF-10 & NPF-15,respectively,consisting of Proposed Tech Spec Change NPF-10/15-275 Re Refueling Interval Surveillances ML19332F0631989-12-0505 December 1989 Informs of Termination of MP Mcdonnell Employment W/Util, Effective 891128 ML19332F1181989-12-0505 December 1989 Provides Schedule for Installation of Diverse Emergency Feedwater Actuation Sys at Plant,Per 890808 Commitment. Schedule for Significant Conceptual Engineering Tasks Completed & Major Tasks to Be Completed Summarized ML20005D7331989-12-0505 December 1989 Advises That RW Dougherty Transferred to Position within Util Which Does Not Require Reactor Operator License, Effective 891204.License OP-50193-1 Expired ML19332D8731989-11-27027 November 1989 Responds to NRC 891027 Ltr Re Violations Noted in Insp Repts 50-361/89-24 & 50-362/89-24.Corrective Actions:Temporary Cables Passing Through Doorway Removed & Maint Order Revised & Reissued to Incorporate Creacus Boundary Requirements ML19332D3261989-11-20020 November 1989 Responds to NRC 891027 Ltr Re Violations Noted in Insp Repts 50-361/89-24 & 50-362/89-24.Corrective Actions:Requirements of Tech Spec 3.0.3 Applied & Applicability Reinforced W/Appropriate Personnel ML19332F4321989-11-15015 November 1989 Forwards Addendums 10-1B & 10-1C to Physical Security Plan. Encl Withheld (Ref 10CFR73.21) ML13304A4381989-11-0909 November 1989 Forwards Proprietary WNEP-8926 & Nonproprietary WNEP-8930, San Onofre Units 2 & 3 Fuel Rack Seismic Analysis for Final Pool Layout. Util Application for Withholding Ltr, CAW-89-104,Proprietary Info Notice & Affidavit Also Encl ML13303B1621989-11-0202 November 1989 Forwards Rev 4 to Amend Applications 78 & 64 to Licenses NPF-10 & NPF-15,respectively,re Spent Fuel Reracking & Proposed Tech Spec on Request from Staff Requiring Min Spent Fuel Pool Boron Concentration ML19325D9781989-10-19019 October 1989 Discusses Completion of Steam Generator Tubing Insp.Total of 4,316 Tubes Inspected & 62 Tubes Removed from Svc by Mechanical Plugging.Insp Significantly Exceeded Amount of Tubing Required to Be Inspected ML19325D1881989-10-0606 October 1989 Informs of Termination of Employment of RA Barnes as Licensed Senior Reactor Operator on 890929 ML20248G6821989-09-29029 September 1989 Advises That Wj Kirkpatrick Employment Terminated on 890922 & License Expired ML20248H1101989-09-29029 September 1989 Advises That Wc Kingsley Employment W/Util Terminated, Effective 890915 1990-08-09
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Certified By_ [) @b Southem Califomia Edison Company P. O. BO X 8 0 0 2244 WALNUT GROVE AVENUE ROSEMEAD CALIFORNIA 9t?70 KENN ETH P. BAS MIN TELEPHONE v1CE PRESIDENT 8I8-302-8400 May 9, 1986 U.S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region V 1450 Maria Lane, Suite 210 Walnut Creek, California 94596-5368 6 Attention: Mr. J. B. Martin, Regional Administrator
Dear Sir:
Subject:
Docket Nos. 50-206, 50-361 and 50-362 NRC Enforcement Actions Related to Inspection Nos. 50-206/85-30; 50-361/85-29; and 50-362/85-28 San Onofre Nuclear Generating Station, Units 1, 2, and 3 By letter dated February 19, 1986, the NRC's Vendor Program Branch
, transmitted to us the results of the NRC environmental qualification audit of San Onofre Units 1, 2 and 3. The report identified seven potential enforcement / unresolved items and six open items. Mr. D. F. Kirsch's letter dated April 2, 1986 issued a Notice of Violation concerning five of the seven potential enforcement items. The purpose of this letter is to respond to the i
Notice of Violation. As discussed between Mr. D. F. Kirsch of your staff and Mr. J. M. Curran of SCE, the response due date was extended one week to May 9, 1986.
Provided as an enclosure is the Southern California Edison Company (SCE) response to the Notice of Violation. 'As indicated, all items related to Unit 1 will be completed prior to return to service of San Onofre Unit 1. The two items related to Units 2 and 3 will be completed by August 29, 1986. At
{ the time of the audit, the items referenced in the Notice of Violation were still considered to be qualified by SCE. As demonstrated in the enclosure, the additional information obtained supported SCE's earlier conclusions i concerning the qualification of the Galite and Rockbestos cable. The qualification package for the Honeywell transducer indicated it was qualified i
' for the environment it would be exposed to in the design basis event. With the exception of the Target Rock solenoid valves, it is our opinion that adequate qualification, as required by 10 CFR 50.49(j), was demonstrated at the time of the audit. Therefore, it is our further opinion that the cable and transducer did not warrant a Notice of Violation.
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Mr. J. B. Martin May 9, 1986 --C:EE In the case of qualification of the Target Rock solenoid valve, the qualified life was based on the assumption the solenoid was deenergized.
During the audit it was determined the solenoid is normally energized. An evaluation of the Target Rock solenoid valves energization status was performed. The solenoids for the affected Target Rock solenoid valves will be replaced and the recalculated qualified life will be included in the qualification package prior to the return to service of San Onofre Unit 1.
I trust the enclosure responds adequately to all aspects of the violations. If you have any questions or if we can provide additional information, please let me know.
Very truly yours, La PM-Enclosure cc: F. R. Huey, USNRC Senior Resident Inspector R. Dudley, USNRC Project Manager, San Onofre Unit 1 H. Rood, USNRC Project Manager, San Onofre Units 2 and 3 4
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ENCLOSURE Response to the Notice of Violation contained in the Enclosure to Mr. D. F. Kirsch's letter of April 2, 1986.
- 1. The enclosure to Mr. D. F. Kirsch's letter of April 2,1986 states:
" 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 lE 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-0508 (Cat. I and II) states that the basis of 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 Galite 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 violation (Supplement I)."
RESPONSE
The test report for the Galite cable demonstrated + hat the insulating material for the cable was capable of withstandin; i design basis event at Units 1, 2 and 3. The cable utilized at the site oas manufactured by Galite, but the cable tested was manufactured by Prestolite Wire and Cable Co. The NRC reviewer of the environmental qualification package indicated that adequate documentation had not been provided which would substantiate the similarity of the processes used by the manufacturers to apply the insulating material to the conductors. Demonstrating similarity between the manufacturers' insulating material was considered not to be sufficient
, by the NRC reviewer.
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l Consistent with industry practice at the time of the audit, under the 00R Guidelines and NUREG 0588 Category II to which the cable was qualified, it j was considered unnecessary to obtain written documentation concerning details of manufacturing similarity once material similarity had been established since all manufacturers conform to the proprietary processes furnished by the insulation polymer supplier. During the audit, the cable manufactur.er was contacted and additional information was obtained which demonstrates the similarity between the Galite and Prestolite processes for applying the insulation material to the conductors.
Corrective Steps Which Have Been Taken and the Results Achieved i
During the audit, the cable manufacturer was contacted and additional
- information was obtained which demonstrates the similarity between the Galite and Prestolite processes for applying the insulation material to the conductors. The environmental qualification packages will be revised to include this additional information.
Corrective Steps Which Will Be Taken to Avoid Further Items of Noncompliance 4
No corrective measures, except for those already described, are required to avoid further items of noncompliance. The methods and procedures used by i ~
SCE to document compliance with appropriate environmental qualification requirements are sound. The perceived discrepancy with the completeness of the Galite cable environmental qualification document packages is not j considered to be a programmatic concern.
Date When Full Compliance Will Be Achieved Full compliance will be achieved when the environmental qualification l document packages for Galite thermocouple extension cable are revised prior to return to service for Unit 1 and by August 29, 1986 for Units 2 and 3.
- 2. The enclosure to Mr. D. F. Kirsch's letter of April 2, 1986 states:
I " 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 recuirements
, 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 QR#1804, which is discredited by IE Information Notice 84-44.
"This is a Severity Level IV violation (Supplement I)."
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RESPONSE
The environmental qualification document package contained a Rockbestos test report for Firewall EP cable. The package indicated that based on this test report, the cable was qualified for use in Unit 1 design basis events. IE Information Notice 84-44 was included in the document package, and even though it alerted the industry to shortcomings in the testing done by Rockbestos, it does not state the cable is not qualified. The Notice indicates the NRC staff concluded that no immediate safety problem exists in the use of Rockbestos cable, and further, indicates that it is the licensee's responsibility to ensure the Rockbestos cable is qualified for the intended use. SCE confirmed with Rockbestos during our initial preparation of the EQ document package for this cable that retesting of the firewall EP cable was in progress. SCE intended to follow the results of this retesting to confirm acceptable res0lts and if necessary, acquire the actual test report for incorporation into the environmental qualification package. We believed this to be an acceptable course of action consistent with those outlined in the Notice. Additionally, based on our review of the Rockbestos test report and the fact that Rockbestos was actively resolving this issue with the NRC, it was, and still is, our opinion that the cable was qualified for use at U. nit I and an acceptable program to resolve any perceived discrepancies was in progress as recommended in IE Information Notice 84-44.
However, as a result of the audit, SCE contacted Niagara Mohawk and purchased Wyle Test Report No. 17722-1 which documents a special test performed on the Firewall EP cable. This report was used to supplement SCE's qualification package.
Corrective SteDs Which Have Been Taken and the Results Achieved Following the audit, SCE contacted Niagara Mohawk regarding the cable testing they had performed. The Firewall EP cable was included in Wyle Test Report No. 17722-1. This test report further supports the environmental qualification document package conclusions that the Firewall EP cable is qualified for use at San Onofre Unit 1. The document package will be revised to include this additional information.
Corrective Steps Which Will Be Taken to Avoid Further Items of Noncompliance !
The corrective actions mentioned above are sufficient to preclude .
reoccurrence of further items of noncompliance. The methods and procedures !
used by SCE to document compliance with appropriate environmental !
qualification requirements are sound. No programm? tic changes to the environmental qualification program are warranted. j Date When Full Compliance Will Be Achieved full compliance with the requirements of 10 CFR 50.49 will be achieved when the environmental qualification document package is revised prior to return to service for Unit 1.
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- 3. The enclosure to Mr. D. F. Kirsch's letter of April 2, 1986 states:
" Paragraph (j) of 10 CFR 50.49 requires that a record of qualification must be maintained to permit verification that each item is qualified i
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 stated that equipment previously required by the Commission to be qualified to the " Guidelines for Evaluating Environmental Qualification for Class lE Electrical Equipment in Operating Reactors" need not be requalified.
- j "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 i 119, at the time of the inspection, the files did not determine
! qualified life based on normal energization; instead life was j determined without consideration for self heating effects that substantially reduced the life.
j "This is a Severity Level IV violation (Supplement I)."
RESPONSE
i i The environmental qualification document package for the Target Rock i solenoid valves indicated a qualified life based on the solenoids being ~
I deenergized. During the audit, it was determined that a Target Rock-l solenoid valve was normally energized. Due to this constant energization, the qualified life for the valve was significantly lower than the original j calculations.
Corrective Steps Which Have Been Taken,and the Results Achieved 4
i A reverification of the energized status of the Target Rock soler.oid valves in the SONGS 1 EQ Program was performed. It was determined that a total of nine Target Rock solenoid valves were normally energized. Consequently, the solenoids for the nine Target Rock solenoid valves will be replaced.
The revised qualified life calculations, along with any other data required to be updated or changed, will be incorporated in the Target Rock Solenoid
- Valve environmental qualification document package prior to the return to service of San Onofre Unit 1.
i Additionally, a reverification of the energized status of the remaining solenoid valves in the SONGS 1 EQ Program was performed. It was determined i
that temperature rise effects due to coil self-heating were adequately addressed in the EQ document packages pertaining to these remaining solenoid valves.
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Corrective Steps Which Will Be Taken To Avoid Further Items of Noncompliance Engineers charged with the performance of activities that could result in configuration changes or modifications will be instructed that consideration shall be given to the effect such changes have on environmental qualification requirements.
Date When Full Compliance Will Be Achieved Full compliance will be achieved when the solenoids are replaced and the environmental qualification document package is revised prior to return to service for Unit 1.
- 4. The enclosure to Mr. D. F. Kirsch's let.ter of April 2, 1986 states:
" 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 lE 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 11150, at the time of the inspection, qualification for a steam environment was based entirely on analysis with no type test.
"This is a Severity Level IV violation (Supplement I)."
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RESPONSE
The environmental qualification document package for the Honeywell transducer indicated that the transducer was qualified by analysis to operate in the design basis event. According to the package, the environment included steam exposure. The reviewer took exception to the
- analysis of a steam environment. An error was found in the section of the document package summary sheets that is used to describe the environment the Honeywell transducer sees following a DBE. Although a steam environment was inadvertently specified, the Honeywell transducer was in fact qualified for the correct design basis event (DBE) to which it would I be exposed. Specifically, the DBE environment is radiation only, and the
, Honeywell document package adequately addressed the transducer qualification for this environment. Therefore, the fundamental qualification of the transducer was indeed valid and the error was limited to a mistake in the document package. The reviewer agreed with the
conclusion stated in the document package that the transducer was qualified when the proper DBE was specified.
Corrective Steps Which Have Been Taken and the Results Achieved Following our review of the package, it was pointed out to the reviewer that the transducer would only be exposed to a radiation environment following a design basis event. The document package adequately addressed this environment by analysis. The transducer is qualified to operate in the design basis event environment. The environmental qualification document package will be revised to reflect this information.
Corrective Steps Which Will Be Taken to Avoid Further Items of Noncompliance The corrective actions mentioned above are sufficient to preclude reoccurrence of further items of noncompliance. The methods and procedures used by SCE to document compliance with appropriate environmental qualification requirements are sound. No programmatic changes to the environmental qualification program are warranted, l
Date When Full Compliance Will Be Achieved Full compliance with the requirements of 10 CFR 50.49 will be achieved when the environmental qualification document package is revised prior to return to service for Unit 1.
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- 5. The enclosure to Mr. D. F. Kirsch's letter of April 2, 1986 states:
" 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.
"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. 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.
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" 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 QR#1803, which is discredited by IE Information Notice 84-44.
b.
The files did not contain test data relevant to the required operating performance characteristics in the plant.
"This is a Severity Level IV violation (Supplement I)."
RESPONSE
The environmental qualification document packages contained a Rockbestos test report for Firewall III cable. The, package indicated that based on this test report, the cable was qualified for use at Units 1, 2 and 3. IE Information Notice 84-44 was included in the document packages, and even though it alerted the industry to shortcomings in the testing done by i
Rockbestos, it does not state the cable is not qualified. The Notice a indicates the NRC staff concluded that no immediate safety problem exists in the use of Rockbestos cable, and further, indicates that it is the licensee's responsibility to ensure the Rockbestos cable is qualified for the intended use. SCE confirmed with Rockbestos during the initial i
preparation of the EQ document packa
! Firewall III cable was in progress. ge for thisscheduled Following cable thatcompletion retesting of the of this j testing in late 1985, SCE planned to obtain the test reports and
- incorporate them into the documentation. We believed this to be an i acceptable course of action consistent with those outlined in the Notice.
i Additionally, based on our review of the Rockbestos test report, and the i fact that Rockbestos was actively resolving this issue with the NRC, it
{ was, and still is, our opinion that the cable was qualified for use at 4 Units 1, 2 and 3 and an acceptable program to resolve any perceived discrepancies was in progress as recommended in IE Information Notice 84-44.
t Corrective Steps Which Have 8een Taken and the Results Achieved i
Following the audit, the Bechtel Quality Assurance files which pertained to the obtained.
testing of the factory reworked Rockbestos Firewall III cable were The most recent Rockbestos test reports, QR #5804 and 5805, which included the Firewall III cable, have also been obtained. This '
additional documentation supports the conclusions contained in the environmental qualification packages that Firewall III cable is qualified for use at San Onofre Units 1, 2 and 3.
Corrective Steps Which Will Be Taken to Avoid Further Items of Noncompliance l
The corrective actions mentioned above are sufficient to preclude j reoccurrence of further items of noncompliance. The methods and procedures
! used by SCE to document compliance with appropriate environmental qualification requirements are sound. No programmatic changes to the environmental qualification program are warranted.
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Date When Full Compliance Will Be Achieved Full compliance will be achieved when the environmental qualification document packages for Rockbestos firewall III cable are revised prior to return to service for Unit 1 and by August 29, 1986 for Units 2 and 3.
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