ML20199E821

Ack Receipt of 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

ML20199E821
Person / Time
Site:	San Onofre
Issue date:	06/18/1986
From:	Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:	Baskin K SOUTHERN CALIFORNIA EDISON CO.
Shared Package
ML20199E825	List: ML20199E821 ML20199E827
References
TAC-42516, NUDOCS 8606240096
Download: ML20199E821 (3)

See also: IR 05000206/1985030

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, JUN 181986

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! Docket Nos. 50-206, 50-361 and 50-362

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, Southern California Edison Company '

P. O. Box 800 , r

2244 Walnut Grove Avenue:

Rosemead, California '9177,0

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l Attention: Mr. Kenneth P.'Baskin,'Vice President

Nuclear Engineering, Safety and Licensing Department

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Gentlemen:

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Thank you for your letter. dated May 9,1986, informing us of the steps you

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

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we still consider all five Severity Level IV violations remain valid. Your

corrective actions will be verified during a future inspection.

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Your cooperation with us is appreciated.

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Sincerely,

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Orlpinoi signe'd b'y

D. 'F."KEfifdh, Director

Division of Reactor Safety

and Projects

Enclosure:

} 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

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PJohnson/ norma AEC affee DFKirsch

/86 /86 86

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8606240096 860618

PDR ADOCK 05000206 TCO

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COMMENTS ON SOUTHERN CALIFORNIA

EDIS0N LETTER OF MAY 9, 1986

The licensee's letter of May 9,1986 responded to the Notice of Violation of

the subject equipment qualification inspection as transmitted by the NRC

letter of April 2,1986. The notice contains five Severity Level IV viola-

tions. After reviewing the response, we conclude that all five items remain

at Severity Level IV; however, the corrective actions are considered accep-

table and subject to verification of them, the items may be closed.

Each of the five violations involves failure to have in place, at the time of

the inspection in September 1985, documentation fully establishing the environ-

mental qualification of equipment installed in the plants. Details of the

violations are provided in the inspection report and Notice of Violation. The

following comments address specific points raised in the licensee's May 9

response, i

1. Galite cable - The file based qualification to 00R Guidelines and NUREG

0588 Category II on type testing of cable manufactured by a different

supplier using identical fluoropolymer insulation material. Although the

licensee states that all manufacturers conform to the proprietary process

furnished by the insulation polymer supplier, not all of the process

conditions utilized in the manufacture of cable are defined in detail by

the polymer supplier. Variations among cable manufacturers' processes

could result in differences such as bonding of the insulation to the

cable conductors, wall thicknesses, or even the use of fillers or adders,

that could affect cable qualification. The licensee's response states

that the cable manufacturer was contacted during the inspection and

additional information was obtained which adequately demonstrates simi-

larity of the two manufacturers' processes. Although the NRC inspectors

have not reviewed that information, we agree that subject to our verifi-

cation its incorporation into the documentation files may be sufficient

to complete qualification of the Galite cable to the D0R Guidelines and

NUREG 0588 Category II.

2. Rockbestos Firewall EP cable - The file based qualification on a Rockbestos

test report discredited by IE Information Notice 84-44. The 1.icensee

states that IN 84-44 does not say that the cable is not qualified, and

that it states no immediate safety problem exists and that the licensee

is responsible for ensuring qualification for the intended use. 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 50.49.

IN 84-44 also suggests possible courses of corrective action, one of which

is to obtain data from other available qualification tests. The licensee's

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response states that this course was followed as a result of the audit, and

subject to our verification it may well be a satisfactory approach. The

licensee's prior actions--following the course of Rockbestos retesting--

were not sufficient to establish qualification in a timely manner.

3. Target Rock solenoid valve - The deficiency involves failure to consider

the effects of self-heating on qualified life. We do not dispute the

licensee's statement that this equipment was considered qualified at the

time of the inspection, since the concern involves an apparent oversight,

and the licensee does not dispute the existence of a violation. Subject

to our verification, the corrective actions identified in the licensee's

response are considered fully responsive.

4. Honeywell E/P transducer - The file claimed qualification for a steam

environment based on analysis, with no type test. During the inspection

the licensee stated that the document package summary sheets contained an

error, and in fact the only harsh environmental parameter is radiation.

The licensee's response states that, although an error was made in documenting

the environmental conditions, the equipment really was qualified. In fact,

the licensee's qualification documentation was deficient because it did not

adequately establish qualification for the defined environment conditions.

Simply stated, the licensee did not meet his burden of documenting qualifi-

cation of the equipment. Subject to our verification, the indicated

corrective action is acceptable.

5. Rockbestos Firewall III cable - This violation is similar to item 2 above.

It differs in that additional test data were subsequently obtained from

Rockbestos, rather than from another licensee. The same comments apply.

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