ML19325E818
| ML19325E818 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/30/1989 |
| From: | Warnick R Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML19325E817 | List: |
| References | |
| 50-445-89-73, NUDOCS 8911090062 | |
| Download: ML19325E818 (3) | |
Text
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APPENDIX A
'l NOTICE OF VIOLATION p
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TU Electric.
Docket:
50-445/89-73
,.c Comanche ~ Peak Steam Electric Station Permit:
CPPR-126
,j Unit 1, Glen Rose, Texas During an NRC inspection. conducted on September 6 through October 3, 1989, violations of NRC requirements were identified.
In accordance with the " General Statement of Policy and Procedure for NRC
- Enforcement Actions," 10 CFR Part 2, Appendix C (1989), the violations-are listed belcw:
D A.,
Criterion V of Appendix B to 10 CFR Part 50, as implemented by i
Section 5.0, Revision 1, of the TU Electric Quality' Assurance
. Manual, requires that activities affecting quality shall be prescribed by and accomplished in accordance with documented instructions, procedures, or drawings.
Paragraph 15.1 of TU Electric Specification 2323-MS-85 states, in part, " Welding and brazing procedures, welders, and welding operations shall be qualified in accordance with AWS D.l.1, Structural Welding Code," which requires shielded metal arc welding processes for joints classified as " structural steel" square groove butt welds.
m Contrary to the above:
The square grove butt welds on the companion angle finnges of the heating, ventilation, and air-conditioning (HVAC) system which were required to be welded using the shielded metal arc welding Fh process were determined to have been welded using the gas metal i
arc welding process.
-This is a Severity Level IV violation (Supplement II) 7 n
-(445/8973-V-01).
B.
Criterion XVII of Appendix B to 10 CFR Part 50, as implemented by Section 17.0, Revision 1, of the TU Electric Quality Assurance Manual, requires that measures shall be established to assure that sufficient records to furnish evidence of the quality of items and of activities afLacting quality are maintained.
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F Paragraph'6.3.3 of TU Electric Procedure CHV-101 states, in part, l
" complete the applicable portions of the welding checklist in i -
accordance with Figure 7.1, HVAC Welding Checklist Entry L
Instructions."
il Contrary to the above:
The weld records for the companion angle flanges of the F.VAC
- system which were required to provide evidence of activities affecting quality were determined to be inaccurate in that welders signed for shielded metal arc welds (SMAW) which they had not performed, as indicated by discrepancies in the applicant's i
- welding checklist continuation sheets.
This is a Severity Level IV violation (supplement II)
(445/8973-V-02).
J In responding to this violation, the applicant is requested to address'the certification implications of welders utilizing the shielded metal arc welding (SMAW) process in that the inaccuracies of the applicant's weld records may have resulted in i
safety-related welds which utilize this process being performed by' uncertified welders.
C.
Criterion XVI of Appendix B to 10 CFR 50, as implemented by Section 16, Revision 1, of the TU Electric Quality Assurance Manual states, in part, " Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.
Contrary to the above:
The applicant failed to take prompt corrective action in response to the identification of conditions adverse to quality subsequent to the determination that procedural noncompliances had occurred during the fabrication of HVAC duct flanges which were identified i
l by TU Electric Corporate Security on July 18, 1989, but which were not acted upon expeditiously by TU Electric management until this issue was identified at the NRC exit on October 3, 1989.
This is a Severity Level IV violation (supplement II)
(50-445/8973-V-03).
L Pursuant to the provisions of 10 CFR 2.201, TU Electric is hereby i
required to submit a written statement or explanation to the U. S.
j Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC, 20555, with a copy to the Assistant Director for Inspection Programs, Comanche Peak Project Division, Office of Nuclear Reactor Regulation, within 30 days of the date of the letter transmitting this Notice.
This reply should be clearly marked as a j
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" Reply to a Notice of Violation" and should include for each h i violation:
(1) the reason for the' violation if admitted, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved.
If an adequate reply is not received within the time specified in this Notice, an order may be issued to show cause why the license should not be modified, suspended, or revoked or why such other action as may be' proper should not be taken.
Where good cause is shown, consideration will be given to extending the response time.
FOR THE FUCLEAR REGULATORY COMMISSION R F u) A Dated at Comanche Peak Site this 30th day of October 1989 l
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