ML20214R925

Notice of Violation from Insp on 861101-1231

ML20214R925
Person / Time
Site:	Comanche Peak
Issue date:	06/01/1987
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20214R909	List: ML20214R906 ML20214R925 ML20214R935 ML20214R963
References
50-445-86-31, NUDOCS 8706090057
Download: ML20214R925 (2)

Text

& O APPENDIX A NOTICE OF VIOLATION Texas Utilities Electric Company Docket: 50-445/86-31 Comanche Peak Steam Electric Station, Permit: CPPR-126 Unit 1 During an NRC inspection conducted on November 1 through December 31, 1986, one violation of NRC requirements was identified. The violation involved the use of an incorrect justification for a "use-as-is" disposition of a nonconformance report (NCR). In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1986), the violation is listed below:

Criterion XV of Appendix B to 10 CFR Part 50, as implemented by Section 15.0, Revision 5, dated October 15, 1985, of the TUGCo 0A Plan, requires that measures be established to prevent the inadvertent use of nonconforming items, and that these measures include procedures for identification, documentation, segregation, disposition, and notification to affected organizations. It further requires that nonconforming items be reviewed and accepted, rejected, repaired, or reworked in accordance with documented procedures.

Paragraph 2.2.2 in TUGCo Nuclear Engineering Instruction TNE-AD-5-2, Revision 3, states, in part, with respect to the dispositioning of NCR, "The disposition shall clearly state what actions are necessary to resolve the nonconforming condition identified . . . . Use-As-Is Dispositions shall include sufficient Engineering technical justification to establish that the nonconforming characteristics will result in no adverse conditions . . . For repair and Use-As-Is dispositions, the required design change shall be initiated per the applicable TNE procedures . . . ."

Contrary to the above, TUGCo Nuclear Engineering's technical evaluation of NCR M-83-101128, Revision 0, pertaining to reported excessive reinforcement and undercut in containment liner welds, indicated that radiographic examination (RT) of the welds in question was part of the justification for the use-as-is disposition, although RT film for the specific weld areas identified by the NCR does not exist. Furthermore, a design change was not initiated to implement the use-as-is disposition.

! This is a Severity Level IV violation. (Supplement II)(445/8631-V-01)

I Pursuant to the provisions of 10 CFR 2.201, Texas Utilities Electric Company is hereby required to submit to this office, within 30 days of the date of the letter transmitting this Notice, a written statement or explanation in reply, including for each violation: (1) the reasons for the violations if admitted, (2) the corrective steps which have been taken and the results achieved, 8706090057 870601 PDR ADOCK 05000445 0 PDR

2 (3)thecorrectivestepswhichwillbetakentoavoidfurtherviolations,and (4) the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending your response time.

Dated at Arlington, Texas this 1st day of June,1987 l

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