ML20148F876
| ML20148F876 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 06/03/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20148F862 | List: |
| References | |
| 50-445-97-09, 50-445-97-9, 50-446-97-09, 50-446-97-9, NUDOCS 9706050076 | |
| Download: ML20148F876 (2) | |
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ENCLOSURE 1 NOTICE OF VIOLATION TU Electric Docket Nos.:
50-445 50-446 Comanche Peak Steam Electric Station License Nos.:
NPF-87 NPF-89 During an NRC inspection conducted on March 17-21,1997, one violation of NRC requirements was identified, in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below:
Criterion IX of Appendix B to 10 CFR Part 50 states, in part, " Measures shall be established to assure that special processes, including... nondestructive testing,
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are controlled and accomplished.. using qualified procedures in accordance with applicable codes, standards, specifications, criteria, and other special requirements."
Section 6.1.1 of Procedure STA-733, " Steam Generator Tube Examination,"
Revision 2 through Procedure Change STA-733-R2-5, estates, in part, "A tube examination using ET techniques qualified in accordance with Appendix "H" of reference 3.15 [ Electric Power Research Institute Pu' lication 'PWR Steam Generator o
Examination Guidelines,' Revision 4, shall be performed on each tube selected...."
Section H.2.1.1 of Appendix H of EPRI TR-106089-V1, "PWR Steam Generator Examination Guidelines," Revision 4, states, in part, with respect to the acquisition technique specification (ACTS), " ACTS shal! define the following essential variables i
as a single value, range of values or formula... Analog cable type and length including: (a) probe cable type and length, and (b) extension cable type and length." Section H.3.3 of Appendix H of EPRI TR-106589-V1, Revision 4, states, in part, "When a change in an acquisition technique... causes an essential variable to exceed a qualified range, the acquisition... technique shall be requalified for the revised range."
Contrary to the above, ACTS Sheet TBX-02-196, which pertained to acquisition of plus point probe examination data from the expansion transition, tube support plate, and free span regions of Unit 1 steam generator tubing during the fifth refueling outage, specified the following changes in the analog cable type and length essential variable without requalification being performed:
1.
An 83-foot length of Type RG 174/U prcbe cable was specified by the ACTS sheet to be used rather than the 50-foot length of Zetec high performance cable that was used in the essential variable qualification.
2.
A 110-foot length of Type RG 174/U extension cable was specified by the ACTS sheet to be used rather than either the 110 feet of Westinghouse cable or 100 feet of Zetec low loss cable that were used in the essential variable qualification.
l 9706050076 970603 PDR ADOCK 05000445 PDR a
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.. This is a Severity Level IV violation (Supplement 1)(50-445/9709-01).
Pursuant to the provisions of 10 CFR 2.201, TU Electric is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, D.C. 20555 with a copy to the Regional j
Administrator, Region IV,611 Ryan Plaza Drive, Suite 400, Arlington, Texas 76011, and a l
copy to the NRC Resident inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation, (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. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response. If an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued as to 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.
Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards -
information so that it can be placed in the PDR without redaction. However, if you find it necessary to include such information, you should clearly indicate the specific information that you desire not to be placed in the PDR, and provide the legal basis to support your request for withholding the information from the public.
Dated at Arlington, Texas this 3rd day of June 1997 l
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