ML20149G341
| ML20149G341 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 07/21/1997 |
| From: | Howell A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Terry C TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| References | |
| 50-445-97-09, 50-445-97-9, 50-446-97-09, 50-446-97-9, NUDOCS 9707230157 | |
| Download: ML20149G341 (3) | |
See also: IR 05000445/1997009
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NUCLEAR REGULATORY COMMISSION
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REGloN IV
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611 RYAN PLAZA DRIVE, SulTE 400
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July 21, 1997
Mr. C. L. Terry
TU Electric
Group Vice President, Nuclear
ATTN: Regulatory Affairs Department
P.O. Box 1002
Glen Rose, Texas 76043
SUBJECT:
NRC INSPECTION REPORT 50-445/97-09;50-446/97-09
Dear Mr. Terry:
Thank you for your letter of June 30,1997, in response to our letter and the attac d
Notice of Violation dated June 3,1997. As a result of our review, we find that additional
information, as discussed with Mr. Obaid Bhatty (during a telephone call on July 8,1997)
is needed. Specifically, please provide further details regarding the nature of the actions
that will be taken to assure that eddy current contractors will conform to program
requirements while conducting steam generator inservice inspections.
Please provide the supplemental information within 30 days of the date of this letter.
Sincerely,
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Arthur T. Howe i Ill, Director
Division of Reactor Safety
Docket Nos.: 50-445;50-446
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cc:
Mr. Roger D. Walker
TU Electric
Regulatory Affairs Manager
P.O. Box 1002
Glen Rose, Texas 76043
9707230157 970721
ADOCK 05000445
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Juanita Ellis
President - CASE
- 1426 South Polk Street
Dallas, Texas 75224
TU Electric
Bethesda Licensing
3 Metro Center, Suite 610
Bethesda, Maryland 20814
George L. Edgar, Esq.
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1800 M. Street, NW
Washington, D.C. 20036
G. R. Bynog, Program Manager /
Chief Inspector
Texas Department of Licensing & Regulation
Boiler Division
P.O. Box 12157, Capitol Station
Honorable Dale McPherson
County Judge
P.O. Box 851
Glen Rose, Texas 76043
Texas Radiation Control Program Director
1100 West 49th Street
John Howard, Director
Environmental and Natural Resources Policy
Office of the Governor
P.O. Box 12428
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Log # TXX 97142
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File # 10130
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IR 97 09
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TUELECTRIC'
June 30, 1997
C. Lance Terry
c+.nsc=4fuclear Regulatory Commission
Attn..:
Document Control Desk
Washington, D.C.
20555
SUBJECT:
C0HANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET N0. 50 445 and 50 446
NRC INSPECTION REPORT NOS. 50 445/97 09 and
50 446/97 09
RESPONSE TO NOTICE OF VIOLATION
TV Electric has reviewed the NRC's letter dated June 3, 1997, concerning
the inspection conducted by your staff which was completed on
March 21, 1997. The subject inspection report enclosed a Notice of
Violation.
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Via the attachment. TV Electric accepts the violation and is responding to
the specific Notice of Violation (445/9709 01). Should you have any
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comments or require additional information, please do not hesitate to
contact Obaid Bhatty at (817) 897 5839 to coordinate this effort.
Sincerely,
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C. L. Terry
By:
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Rogerd1. Walker
Manager, Regulatory Affairs
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Attachment
cc: Mr. E. W. Herschoff, Region IV
Hr. J. I. Tapia, Region IV
Resident Inspectors
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Attachment to TXX-97142
Page 1 of 2
RESPONSE TO THE NOTICE OF VIOLATION
RESTATEMERT OF THE VIOLATION
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(50 445(446)/9709 01)
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Criterion IX of Appendix B to 10 CFR Part 50 states, in part, "Heasures
shall be established to assure that special processes, including.,
nondestructive testing, are controlled and accomplished...using qualified
procedures in accordance with applicable codes, standards, specifications,
criteria, and other :pecial requirements."
Section 6.1.1 of Procedure STA 733, " Steam Generator Tube
Examination," Revision 2 through Procedure Change STA 733 R2-5,
states, in part. A tube examination using ET techniques qualified in
accordance with Appendix 'H' of reference 3.1.5 Electric Power
Research Institute Publicatioa 'PWR Steam Generator Examination
Guidelines,' Revision 4, shall be performed on each tube selected. .
Section H.2.1.1 of Appendix H of EPRI TR 106589 V1, "PWR Steam
Generator Examination Guidelines,' Revision 4, states, in part, with
' ACTS
respect to the acquisition technique specification (ACTS),
shall define the following essential variables as a single value,
rango 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 1 96, 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 probe 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.
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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.
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AttacNnent to TXX-97142
Page 2 of 2
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RESPONSE TO THE VIOLATION
(50 445(446)/9709 01)
TV Electric accepts the violation and the requested information is
provided herein.
Reason for Violation
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TV Electric wishes to clarify the circumstances associated with the
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Notice of Violation. ACTS TBX 02196 specified probe cable and
extension essential variables which were not adhered to during the
steam generator tubing eddy current testing (ECT) during the fifth
refueling outage of Unit 1 (1RF05).
ACT TBX 02196 specified the probe cable to be type RG174U with a
maximum length of 83 feet, and an extension cable to be type RG1740
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with a maximum length of 110 feet.
The cable type actually used to
collect steam generator tube ECT data during 1RF05 was an 83 foot
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length of Zetec low loss cable for the probe cable and a 50 foot
length of Zetec low loss cable for the extension cable. The
qualification of the system utilized a 50 foot length of Zetec low
loss cable for the probe cable and a 100 foot length of Zetec low
loss cable for the extension cable.
The total cable length
qualified was 50 + 100 = 150 foot.
The total cable length used was
83 + 50 - 133 foot.
Therefore TV Electric concluded that the ECT
data collected with the system utilized during 1RF05 met the
requirements of the PWR Steam Generator Examination Guideline
Revision 4 Volume 1. Appendix H paragraph H.3.2.
Notwithstanding, TV Electric believes that the cause for the
violation was less than adequate review of ACTS TBX 02196 against
the requirements of Appendix H, and failure to verify equipment
prior to use. The reviewer did not recognize that ACTS was in
conflict with the existing Appendix H qualification, and no physical
verification of the equipment was performed prior to use.
2.
Corrective Steos Taken and Results Achieved
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The condition was evaluated by l0 Electric engineering. and it was
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concluded that the actual cables used versus the actual cables
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qualified would have no discernible effect on data quality.
This
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violation and its response was reviewed by the cognizant individuals
as lessons learned.
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3.
Corrective Actions Taken to Preclude Recurrence
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TU Electric will revise work control documents to verify that the
ECT equipment is approved for use prior to commencing work in the
field.
4.
Date of Full Comoliance
TU Electric is in full compliance.