ML19332B954
| ML19332B954 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 11/17/1989 |
| From: | William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TXX-89812, NUDOCS 8911220110 | |
| Download: ML19332B954 (4) | |
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. Log # TXX-89812
.7 File # 10130
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1 IR 89-f.6 C
C Ref. # 10CFR2.2Cl nlELECTRIC November 17, 1989 5NA$$$o U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C.
20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50-446 NRC INSPECTION REPORT NO. 50-445/89-66; 50-44S/09-66 RESPONSE.TO NOTICE OF VIOLATION Gentlemen:
TU Electric has reviewed your letter dated September 26, 1989, concerning the inspection conJucted by Mr... Stanish and another NRC consultant during the period August 2 through September 5, 1989. This inspection covered activities authorized by NRC Constructien Permits CPPR-126 and CPPR-127 for CPSES Units 1 and 2.. Attached to the NRC letter was a Not,1ce of Violation.
On October 25, 1989, in a discussion between Mr. R. F. Warnick of the NRC and Mr. D. E. Noss and Mr. D. P. Barry cf TU Electric, it was agreed that TV Electric's response to Notice of Violation 445/8966-V-Ol; 446/8556-V-01 would be submitted by November 17, 1989.
TU Electric hereby responds to the Notice of Violation in the attachment to this letter.
Sincerely, l
YbhnhS1b$f William J. Cahill, Jr.
By:
t2A M Roger 3. Walker Manager, Nuclear Licensing HAM /cp Attachment c - Mr. R. D. Martin, Region IV Resident Inspectors, CPSES (3) k
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- 'fl 400 North Olwe Stitet LB81 Dallas, Texas 73201
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Attachment to TXX-89812 Page 1 of 3 NOTICE OF VIOLATION (445/8966-V-01;446/8966-V-01)
Criterion XVI of Appendix B to 10CFR 50, as implemented by Section 16 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 noncenformances are promptly identified and corrected...."
Paragraph 6.2.2 of TU Electric Procedure ECE 9.01 states, in part, " Adverse conditions shall be evaluated for reportability under 10 CFR 50.55(e)...
justification as to why the adverse condtion is or is not reportable shall be thoroughly documented...."
Further, Attachment 8.C of TU Electric Procedure ECE 9.01 entitled, i
" Guidelines for Determining Reportability (10 CFR 50.55[e]) defines a reportable deficiency as "A significant deficiency in construction or a significant damage to a structure, system, or component which will require extensive evaluation, extensive redesign, or extensive repair to meet the criteria..."
Contrary to this:
A.
Manufacturing defects which required repairs to more than one hundred and fifty feet of seam welds it, structural tubing installed in the service water tunnel were erroneously identified as non-extensive installation deficiencies which severely limited the review for generic implications.
B.
For the structural tubing found to violate the minimum requirements of ASTM A500, the review performed was limited to the specific sections of tubing identified with no review performed for potential generic implications.
RESPONSE TO NOTICE OF VIOLATION (445/8966-V-Ol; 446/8966-V-01)
TU Electric accepts the violation and the requested information follows:
1.
Reason for the Violation The TU Electric final report provided for Significant Deficiency Analysis Report (SDAR) CP-88-28 did not adequately describe the engineering basis for the conclusions reached regarding the determination that the indications identified by Ultrasonic Testing (UT) in tubing weld seams and thin wall tubing did not represent reportable deficiencies. While that conclusion has been determined to be correct, a sufficiently documented basis was not developed to support the conclusions reached.
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Attachment to TXX-89812 Page 2 of 3
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2.
Corrective Steos Taken and Results Achieveu As a result of this violation, the following actions have been taken to determine the adequacy of the bases for the conclusions reported in SDAR
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Regarding the UT indications identified in the structural tube steel weld
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seams, additional UT examinations, physical testing, and evaluation of the subject heats have been performed. The results of this effort have been 4
documented and included in a revision to the engineering report prepared for tube steel weld seams. This report affirms that the UT indications identified in the tube seam welds were not reportable untfer 10CFR50.55(e) because the tube steel would have performed its intended function.
Physical testing (cone expansion) af other tube steel heats was also performed to determine the adequacy of tube steel supplied to CPSES.
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i sample selection, testing, and test results are discussed in the engineering report described above. The cone expansion test results 1
indicate that the additional heats were also acceptable.
Regarding the thin wall structural tube steel issue, additional UT l
measurements were performed and the results evaluated, documented, and l
included in a revision to the engineering report prepared for the evaluation of tube steel thinning and corner cracking.
The additional UT was performed on materials supplied by the subject vendor prior to implementation of the enhanced receipt inspection methods described in the 5DAR CP-08-28 final report. The basis for limiting additional UT to one vendor is also included in the engineering report. No significant deficiencies were identified by the additional UT performed on other heats of tube steel used at CPSES.
The NRC Inspector noted that the thin wall tube steel issue described in SDAR CP 88-28 had not been identified by inspection upon receipt of the i
material at CPSES.
Prior to January 1988, TV Electric did not employ receipt inspection methodology that could verify tube steel wall thickness along the length of the tube; therefore, additional UT measurement of wall thickness during receipt inspection was implemented in January 1988.
3.
Corrective Steos Taken to Avoid Further Violation 1 The additional evaluations described above substantiated the conclusions contained in the final report for SDAR CP-88-28.
To preclude recurrence of the condition which led to this violation, personnel responsible for SDAR evaluations are being directed to assure that an adequately documented basis exists for non-reportability determinations on SDARs.
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Attachment to TXX-89812 Page 3 of 3 In addition, a management review committee was established in November 1989 to provide additional assurance that TU Electric evaluations of and corrective actions for reportable deficiencies are thorough and i
comprehensive. The review committee is comprit:ed of a representative from 4
Quality Assurance, Engineering and Licensing.
The purpose of the committee is to confirm the correctness of the root cause(s) and the adequacy of the corrective action (s) for 10CFR50.55(e) reportable conditions by review of substantiating information.
This action is sufficient to avoid further violations.
4.
Date of Full Comoliance CPSES is currently in compliance.
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