ML19309H764

Responds to NRC 800402 Ltr Re Violations Noted in IE Insp Repts 50-445/80-08 & 50-446/80-08.Corrective Actions:Rept Has Been Prepared & Reporting Requirements Have Been Clarified

ML19309H764
Person / Time
Site:	Comanche Peak
Issue date:	04/21/1980
From:	Gary R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	Seidle W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML19309H755	List: ML19309H764
References
TXX-3129, NUDOCS 8005190690
Download: ML19309H764 (3)

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' O. TEXAS UTILITIES GENERATING COMPANY j noon nayus Towca naus.ruxas n2oi j a.; cany . April 21, 1980 "1J12," .'l." "'.!!l:' 'TXX-3129 Mr. W. C. Seidle, Chief Reactor Construction and Engineering Support Branch U. S. Nuclear Regulatory Commission Office of Inspection & Enforcement 611 Ryan Flaza Dr., Suite 1000 Docket Nos. 50-445/80-08 Arlington, Texas 76012 50-446/80-08 ,

COMANCHE PEAK STEAM ELECTRIC STATION 1981-83 2300 MW INSTALLATION .

RESPONSE TO NRC NOTICE OF VIOLATION ,

INSPECTION REPORT N0. 80-08 DOCKET N05. 50-445 & 50-446 j FILE NO: 10130 l

Dear Mr. Seidle:

We have reviewed the report dated April 2, 1980 on the inspection activities performed by your resident inspector, Mr. R. G. Taylor, of the activities authorized by NRC Construction Permit No. CPPR-127 for the Comanche Peak facility, Unit No. 2. We have responded to the findings listed in Appendix A of that report.

To aid in the understanding of our response, we have repeated the require-ment and your findings followed b;y our corrective action.

We believe the attached information to be responsive to the Inspector's findings. If you have any questions, please advise.

Very truly yours, R.d. Gary Attachment 1 RJG:df

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Inspection Report No. 80-08 TXX,3129 Page 2 APPENDIX A NOTICE OF VIOLATION Based on the results of an NRC appraisal of your action during the period of December 13, 1979 to present, it appears that certain of your activities were not conducted in full compliance with the conditions of your NRC Con-struction Permit No.127 as indicated below:

Failure to Report a Significant Construction Deficiency ,

, 10 CFR 50.55(e) (1) states: "If the permit is for construction of a nuclear power plant, the holder of the permit shall notify the Commission of each deficiency found in design and construction, which, were it to have remained uncorrected, could have affected adversely the safety of j operations of the nuclear power plant at any time throughout the I expected lifetime of the plant, and which represents:

(iii) A significant deficiency in construction of or significar.t damage to a structure, system, or component which require extensive evaluation, extensive redesign, or extensive repair to meet criteria

and bases stated in safety analysis report or construction permit or to otherwise establish the adequacy of the structure, system, or component to perform its intended safety function . . . ."

10 CFR 50.55(e) (3) further states: "The holder of a construction permit shall also submit a written report on a reportable deficiency within thirty (30) days to the appropriate NRC Regional Office . . . ." 'If

. sufficient information is not available within 30 days, an interio rvport containing all available information shall be filed, together with a statement as to when a complete report will be filed."

Contrary to the above:

On December 13, 1979, the Permit Holder notified the NRC Resident Reactor Inspection (RRI) that attempts to remove concrete " honeycomb" in certain interior walls of the Unit Two Containment Building had developed into an unexpectedly difficult deficiency. The Permit Holder also informed the RRI that a consultant would be employed to perform a sonic (microseismic) investigation of the walls involved.

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Inspection Report No. 80-08 TXX-3129 Page 3 On January 17, 1980, the Permit Holder notified the RRI that the sonic i investigation was complete and that the Architect / Engineer was evaluating the results along with visual exaninations.

Beginning in December 1979, the Permit Holder has performed extensive engineer- ,

ing evaluations either for the purpose of establishing the methods of repair ]

or for evaluating the adequacy of the structure without repair, yet the Permit "

Holder has failed to furnish the NRC Regional Office with either an interim or final written report on this matter within the time period set forth in 10 CFR 50.55(e). {

Corrective Steps Which Have Been Taken and Results Achieved We have prepared a written report documenting information previously presented to your Resident Inspector verbally. This report is being transmitted under separate letter number TXX-3124, dated April 21, 1980.

Corrective Steps Which Have Been Taken to Avoid Further Noncompliance We have reviewed requirements for submitting written reports in accordance with 10 CFR 50.55(e) as described in the NRC guidance document as presented to us by your Resident Inspector and as discussed in our meeting on April 8, 1980. This review has resulted in a clarification of reporting requirements which has been discussed with appropriate personnel in our organization to preclude further noncompliance.

Date of Full Compliance Full compliance is effective as of the date of this report.

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