ML17317B536
| ML17317B536 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 07/27/1979 |
| From: | Dolan J INDIANA MICHIGAN POWER CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML17317B535 | List: |
| References | |
| 00239, 239, NUDOCS 7909180262 | |
| Download: ML17317B536 (5) | |
Text
INDIANA R MICHIGAN POWER COMPANY P. O. BOX 18 BO WL I N G G R E EN STAT ION NEW YORK, N. Y. 10004 July 27, 1979 AEP: NRC:00239 Donald C.
Cook Nuclear Plant Units No.
1 8
2 Docket Nos.
50-315 and 50-316 Recense Nos.
DPR-58 and DPR-74 Mr. James G. Keppler, Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137
Dear Mr. Keppler:
This letter is i n response to Mr. G. Fiorelli's letter of July 3, 1979 received July 9, 1979 and which transmitted IE Report No. 50-315/79-10 and 50-316/79-07.
The attachment to this letter contains the information requested by Mr. Fiorelli's letter regarding the infraction which appeared to be i n non-compliance with NRC requirements.
Very truly yours, JED:clb attachment ohn E. Dolan Vice President cc:
R. C. Callen G. Charnoff R. S. Hunter R.
W. Jurgensen D. V. Shaller - Bridqman t
$0~
V II09 1 8OQQ2
D
Res onse to t<otice of Violation described in IE Ins ection Report 50-315 79-10; 50-316/79-07 "On Nay 21, 1979, the inspector observed that the repair of the feedwater nozzle/piping had been started without an established repair procedure.
A procedure for the repair acti vities was developed and issued on i::ay 28, 1979."
The inspector states that excavation of defective areas on th<<
feedwater piping had been observed in proces:
on tlay 21, 1979, without the use of a procedure to adequately control the repair activities.
Prior to the inspector arriving on site on Nay 21, 1979, the ollowing actions had been taken:
a)
On t'lay 19, 1979, the Plant t1aintenance Department requested that tre plant gC Department pe> form a nondestructive examination o
. the cracked area of the nozzle to feedwater elbow weld on the U~il t 2 Steam Generators
-.'1 and d4 to determine the extent of the crac);,
and to see if any other surface indications existed in other areas nea.
these two welds.
Magnetic particle examination was used in this initial examination.
The same welds on Steam Generators
-:2 ar d
..-::3 were also examined using magnetic particle examinations.
Exce..t for the leaking area, the magnetic particle examination did not reveal any other surface flaw indications.
b)
Subsequent to this examination, the Plant Maintenance Departm nt, utilizing Yiaintenance Procedure No.
12 f1HP 5050.SPC.002 Revision 1, dated January 4,
1979, entitled "Piping System Defect Identification and Removal",
commenced grinding.
The use of this procedure is normal practice when piping system defects are evident but the scope of the problem is unknown.
Basically, it addresses excavation and non-destructive examination methods and requirements for determ'.ning the magnitude of' defect.
This procedure was utilized in an attempt to define the magnitude of the defect.
However, it became very apparent that the scope of this defect was not going to be defined using this method.
On Pay 20, 1979, Superior Industrial X-Ray was brought on site to perform a radiographic examination of all the Unit 2 nozzle welds.
This examination revealed indications of flaws in all four nozzles.
Additional examinations requested by the American Electric Power Service Corporation were performed which included removing samples from selected elbows.
These samples were sent to an independent laboratory for'ailure analysis and the performance of a stress examination using a hydroset machine.
~
~-
It was only after all of these exploratory tests and examinations that a repair program was to be formulated.
On t'iay 26, 1979, the Plant gA Supervisor issued a stop work order until a comprehensive repair program procedure was developed.
This procedure, 12 NHP-SP-001, was approved and issued on flay 28, 1979.
From that date until completion of the repair this special procedure was followed.
It is our contention that this notice of violation is unwarranted and that the grinding observed by the inspector did not constitute a repair.
father, the grinding was part of defining the extent of damage which had occurred.
- Hence, the infraction involving an apparent non-compliance with NRC requirements regarding the necessity of utilizing establisl>ed procedures did not occur.