ML20043C309

Responds to NRC 900430 Ltr Re Violations Noted in Insp Rept 50-298/90-15.Util Does Not Believe That Violation Existed & Therefore No Corrective Action Required.Inservice Testing Program Being Enhanced as Result of Insp

ML20043C309
Person / Time
Site:	Cooper
Issue date:	05/30/1990
From:	Trevors G NEBRASKA PUBLIC POWER DISTRICT
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CNSS907252, NUDOCS 9006050041
Download: ML20043C309 (4)

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,em OENERAL OFFICE P.O. BOX 499. COLUMBUS. NEBRASKA 90002-0400 i Nebraska Public Power District TxinlE%'"'  !

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CNSS907252  :

May 30, 1990  ;

q U.S. Nuclear Regulatory Commission Document Control Desk .

Washington, DC 20555  ;

Subject:

NPPD Response to NRC Inspection Report 50 298/90 15 Cooper Nuc1 car 9tation r Docket No. 50 Centlemen:

This letter is written in response to your letter dated April 30, 1990, transmitting Inspection Report 50 298/90 15. Therein you indicated that one of our activities was in violation of NRC requirements.

Following is a statement of the violation and our response.

STATEMENT OF VIOLATION Failure to Include ASME Class 3 Nonintecral Component Supports in the ISI Procram Technical Specification 4.6,0 for Cooper Nuclear Station states, in part, that inservice inspection of ASME Code Class 1, 2, and 3 componcuts shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda.

Paragraph IWD 2620 " Visual Examination VT 3" of Section XI of the ASME code states, in part, that the component supports and restraints within the boundary of each system specified in the examination categories of Table IWD 25001 shall be subject to the visual examination of VT 3 and shall be performed at the frequency specified in Table IWD 2500 1 (which is each inspection interval).

Contrary to the above, Class 3 nonintegral comoonent supports from within the boundary of each system specified in Table IWD 2500 1, were not included in the first and second 10 year ISI program for VT 3 visual examinations.

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. I U.S. Nuclear Regulatory Commission May 30, 1990 Page 2  ;

Reason for the Violation As indicated in Inspection Report 90 15, lengthy discussions have taken place between the NRC and NPPD concerning the interpretation of Section XI '

Code requirements for inspecting Class 3 nonintegral attachments.

Some confusion resulted due to the Code being somewhat ambiguous on the exemption process of Class 3 supports for examination. NPPD's current 10 year ISI Inspection Interval is based on the 1980 Edition Winter 1981 Addenda of Section XI.

i The following is a brief summary of the difference between NPPD's and NRC's interpretation of the exemption process for Class 3 nonintegral component supports.

NPPD's interpretation of the exemption process for Class 3 nonintegral component supports.

Based on IWF 2510, the component supports selected for examination are the supports of those components that are required to be examined under IWD, which are the supports of those non exempt components and non exempt portions of piping within the system boundary that are required to be examined by volumetric, surfar:e, or  ;

visual (VT 1 or VT-3 examination methods). Since a VT 2 examletion is invoked on all components, thereby donying a selection process, the VT 2 examination is not included as an examination method for selecting component supports. (Refer to ASME Interpretation XI 1 83 12R-2 for a clarification of this position.)

A VT 3 of integral attachments is the only examination that is required by IWD which allcws for a selection process. Consequently,.

the Code does not require nonintegral attachments to be examined when integral attachments have been exempted from the VT 3 examination per IWD 1220. ,

NRC Interpretation as indicated in the Violation and Inspection Report.

Paragraph IWD 2620 which states, in part, that the component supports and restraints within the boundary of each system specified in the examination categories of Table IWD 2500 1 shall be subject to the visual examination of VT 3 and shall be performed at the frequency specified in Table IWD 2500 1.

Contrary to the above, Class 3 nonintegral component supports from within the boundary of each system specified in Table IWD 2500 1, were not included in the first and second 10 year ISI program for VT 3 visual examinations.

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. l U.S. Nuclear Regulatory Commission May 30, 1990 Page 3 This position . would require that NPPD examine the nonintegral attachments for components which have their integral attachments exempted.

Af ter receiving the Notice of Violation, NPPD again carefully reviewed Section XI and contacted code experts, including the chairman of the Section XI Working Group on Component Supports to re verify the Code position on exempting nonintegral attachments when the integral attachments have been exempted. In order to formally address this issue, NPPD submitted Inquiry questions, concerning the exemption of nonintegral attachments for examination, to ASME Section XI at their quarterly meetings in Nashville, Tennessee, during the week of May 14, 1990.

NPPD submitted two inquiry questions to the ASME Section XI Code Committee. The first one was concerning the NRC's position that IWD 2620 applies to a VT 3 on nonintegral attachments. IWD 2620 was the paragraph cited in the violation.

Question 1: Is it the: intent of ASME Section XI, that IWD 2620(a) only apply to integral attachments specified in Table IWD 2500 17 Reply; Yes.

This supports NPPD's position that IWD-2620 applies only to the VT 3 specified in Table IWD 2500 1 for examination of the integral attachment (not entire component supports). IVD 2620 was removed from later editions of the Code due to the confusion it created.

The second question asi*ed if any component supports would require examination if that pip h.g 's integral attachments were exempted per IWD 1220.

Question 2: In a Class 3 system, is it the intent of Section XI, IWF 2510, or IWD 2620 to examine component supports for piping which have their integral attachments exempted from examination by IVD 12207 Reply: No.

This also supports NPPD's position.

Based on the explanation provided, including formal concurrence of NPPD's

( inquiry questions from the ASME Section XI code Committee, NPPD respectfully requests that the NRC reconsider this Notice of Violation.

The District contends that this was not a violation of NRC requirements

(. since NPPD's interpretations were not contrary to the requirements of ASME l Section XI or Technical Specification Section 4.6,0.

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9 U.S. Nuclear Regulatory Commission May 30, 1990=

Page 4 Corrective Stens Which Have Been Taken and the Results Achieved The District does not believe that a violation existed, and therefore, no corrective action is required. However, as a result of this inspection, NPPD is enhancing its IST Program to include some Class 3 component i supports which t+7e originally exempted. This enhancement is based on using an "and" sr 13.eu of an "or" requirement. in its interpretation of IWD 1220.2. A1,nough the 1980 Edition Winter 1981 Addenda of Section XI did not have a qualifier between IWD 1220.2(a) and (b), later editions of the Code were changed to include an "and" requirement. NPPD inspected the supports that were associated with integral attachments during the 1990 Refueling Outage.

Corrective Steos Which Will Be Taken to Avoid Further Violations The District does not believe that a violation existed, and therefore, no corrective action is required. However, as an additional program enhancement, a review of our selection process for component supports will be performed.

Date When Full Comoliance Will Be Achieved NPPD is presently in full compliance. The program enhancements will be

-included in out program by the completion of 1991 Refueling Outage.

Please contact me if you have any questions or require any additional info rmation.

Sincerely, 7

. Trevors Division Manager Nuclear Support CAT:BLC:sa cc: Regional Administrator USNRC - Region IV NRC Resident Inspector Cooper Nuclear Station i.-.