ML20248A569

Notice of Violation from Insp on 890802-0905.Violation Noted:Mfg Defects Requiring Repairs Erroneously Identified as Nonextensive Installation Deficiencies Which Severely Limited Review for Generic Implications

ML20248A569
Person / Time
Site:	Comanche Peak
Issue date:	09/26/1989
From:	Joel Wiebe NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20248A507	List: IR 05000445/1989066 ML20248A503 ML20248A569
References
50-445-89-66, 50-446-89-66, NUDOCS 8910020248
Download: ML20248A569 (2)

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APPENDIX A NOTICE OF VIOLATION 1NJ Electric Dockets: 50-445/89-66 50-446/89-66 Comanche Peak Steam Electric Station Permits: CPPR-126 Units 1 and 2, Glen Rose, Texas CPPR-127 During an NRC inspection conducted on August 2 through September 5 1989, a violation of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1989), the violation is listed below:

Criterion XVI of Appendix B to 10 CFR 50, as implemented by Section 16 of the TU Electric Quality Assurance Manual, states, ir part, " Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly idnetified and corrected . . . .

Paragraph 6.2.2 of TU Electric Procedure ECE 9.01 states, in part,

" Adverse conditions shall be evaluated for deportability 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,

" Guidelines for Determining Deportability (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:

i A. Manufacturing defects which required repairs to more than one hundred and fifty feet of seam welds in structural tubing installed in the service water tunnel were erroneously identified as non-extensive installation deficiencies which severely limited the review for generic implications.

8910020248 890926 I PL .1 ADOCK 05000445 0 PDC l

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B. For the structural tubing found to violate the minimum 4 requirements of ASTM-A500, the review performed was limited to the specific sections of tubing identified with_no review performed for potential generic implications.

This-is'a. Severity Level IV violation'(Supplement II)

(445/0966-V-Ol; 446/8966-V-01).

' Pursuant tofthe 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, DC, 20555, with a copy to the Assistant Director for Inspection Programs, Comanche Peak Project Division, Office of Nuclear Reactor Regulation, within 30 days of the date of the letter. transmitting this Notice. This reply should be clearly marked ~as a'" Reply to a Notice of Violation" and should include for cach violation: (1) the reason for the violation if admitted, (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. If an adequate reply is not received within the time specified in this Notice, an order may be issued to show cause 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.

FOR THE NUCLEAR REGULATORY COMMISSION Dated'at Comanche Peak Site this 26th day of September 1989

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