ML20011D526

Provides Revised Response to Violations Noted in Insp Repts 50-445/89-38 & 50-446/89-38.Corrective Actions:Procedure ISI-206 Revised in 1987 to Clearly Require That Geometric Reflector Sources Be Recorded

ML20011D526
Person / Time
Site:	Comanche Peak
Issue date:	12/21/1989
From:	William Cahill, Walker R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
TXX-89859, NUDOCS 8912270359
Download: ML20011D526 (4)

Text

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% l F7 Log # TXX-89859 i C File # 10130 C C 1R 50-445/89 38 M#ELECTR/C IR 50 446/89 38 1 Ref. # 10CFR2.201 1

- y$'" j j.[f$'; December 21, 1989

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U. S..Nucitar Regulutory Commission  :

Attn Document Control Desk '

. Washington, D. C. 20566 ,

SUBJECT:

COMA 6fHE.PEAV,SYEAM ELECTRIC STATION DOCKET NOS. 50 445 AND 50 446 ,

- NRC INSPECTION REPORT NO. 50 445/89-38, 50 446/89 38  !

REVISED RESPONSE TO NOTICE OF VIOLATION 445/8938 V 04, ITEM A

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REF: TU Electric letter TTX 89730, from W. J. Cahill te USNRC, dated Octu'Je" 16, 1989.

Centlement  !

Tne refererced letter provided TU Electric's response to Netice of Oiolation (NOV) Item A (445/8938-V-04), A revi+,ed response is attached. In this revised response, TV Electric clarifias the referenced letter and provides follow-up to a telephone conversation with Messrs. H. Kerch and M. Runyan of the NRC on November 21, 1989. The subject violation identified that a procedural deficiency had resulted in en ultrasonic geometric reflector not being recorded. In the referenced letter, TV Electric stated that the

-procedure was revised to clearly require that geometric reflector sources be recorded. This revised procedure was used for Unit 2 PSI examinations and will be used for the Unit 1 and 2 ISI examinations. In addition. TV Electric stated that an FSAR revision would be submitted to indicate that Unit 1 geometric reflectors would be recorded during the Unit 1 ISI program.

Relief Request B'13, documented in CPSES SSER 12, Appendix S, Paragraph 3.3, dated October 1985, provided relief from recording geometric reflectors during the Unit 1 PSI. Data from ultrasonic reflectors interpreted as flaws, however, would be recorded. The NRC inspector was not made aware of this relief request during the inspection. Since this was an approved exception to Section XI of the ASME Boiler and Pressure Vessel Code, 1980 Edition, which has already been docketed, revising the CPSES FSAR is unnecessary. In addition. TV Electric has implemented the site procedure revision which clearly requires that the appropriate data, including geometric reflectors, will be recorded as the Unit 1 ISI program is implemented.

O ft k .00b445 PDC Q(/

400 North Olive Street LB. El Dallas, Texas 75201 g g J

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TXX 89859 Page 2 of 2 The data that will be gathered for Unit 1 ISI will include welds within the system boundaries as set forth by the ASME Code. The edition of the Code to ,

be utilized for Unit 1 ISI (1986) does not require examination of the portion of the Safety injection System containing weld TBX 2-2523 Number 7.

Therefore, TU Electric has elected not to examine this weld.

Revision bars in the right margin indicate the changed portions of TV e Electric's attached revised response.

Sincerely, W h pps Y)h.

Willints J. Cahill, Jr. ,

By: M 44 0 Y{ '

R. D. Walker Manager, Nuclear Licensing DAR/

Attachment c - Mr. R. D. Martin, Region IV Resident Inspectors. CPSES (3) i l

Attachment to TXX-89859 i

• .Page 1 of 2 1

NOTICE OF /IOLATION ITEM A i (445/8938 V-04)  !

10CFR50, Appendix B, Criterion IX requires that special processes such as ]

nondestructive testing be accomplished using qualified procedures in  ;

accordance with applicable codes. Comanche Peak's FSAR and site  ;

ultrasonic procedure ISI-206, Revision 0, state that preservice '

examinations will be performed in accordance with the ASME Boiler and  ;

Pressure Vessel Code Section XI, 1980 edition. ASME Section XI, paragraph j IWA[-]2232 requires for the examination of welds that " reflectors that 1 produce a response greater than 50% of reference level shall be recorded."

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l Contrary to the above, a review of site procedure 151-206, Revision 0, disclosed the.t the pror:edure has a less stringent recording requirement l than tb&t required by ASME Section XI. Furthtraore, an NRC ultresonic j exam' nation of weld TBXJi 2523, Number 7, an ASME Class 2 weld in the i safety injection system, identified en ultrasonic reflector that p*oduced a response greater ther. 50% of DAC, and as an consequence of the )

inadequate procedure, this reflector had not been recorded nor  ;

dispositioned in accordance with ASME Section XI requirements.

t RESPONSE TO NOTICE OF VIOLATION ITEM A (445/8938 V 04)

TV Electric agrees with the alleged violation and the requested information 4 follows:

1. B12 son for Violation The intent of the ASME Section XI Preservice Inspection (PSI) requirement concerning geometric reflector recordings is to establish a baseline '

record of geometric reflectors for reference during inservice Inspection  ;

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(ISI). Without this baseline, ultrasonic reflectors detected during IS!

would be assumed to be service induced defects unless shown to be a geometric reflector. Procedure ISI-206, Revision 0, did not clearly require that geometric reflectors be recorded. As a result, the geometric i l reflectors, including those observed on weld TBX-2-2523 Number 7, were not recorded during Unit 1 PSI.

l 2. Corrective Steps Taken and the Results Achieved.

l l An independent testing firm ultrasonically tested weld TBX 2-2523 l Humber 7 and confirmed the NRC inspector's finding that this weld did have geometric indications that were required to be recorded.

l Procedure 151-206 was revised in 1987 to clearly require that geometric reflector sources be recorded. The revised procedure was used for Unit 2 PSI examinations. The procedure that will be used for the Unit 1 ISI examinations will also require that geometric reflector sources be recorded. This revision provides assurance that the required baseline data will be recorded as the Unit 1 ISI program is implemented.

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e. Attachment to TXX 89859

. Page 2 of 2  ;

3. Corrective Steps Which Will Be Taken to Avoid Further Violations The current review process for 151 precedur6s prov' ides an additional review by a TU Electric NDE Level III which was not required for Procedure 151 206, Revision O. This additional review provides increased assurance of compliance with ASME Code requirements.

4. Date When Come11ance Will be Achieved

! Full compliance has been achieved.

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