ML20062F508
| ML20062F508 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 11/15/1990 |
| From: | Trevors G NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9011280010 | |
| Download: ML20062F508 (3) | |
Text
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q COoPCH NUCLEAR ST AT80N
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.i November 15, 1990
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U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 l
Subject:
NPPD Response to NRC Inspection Report 50 298/90 15 Cooper Nuclear Station Docket No. 50 298
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References:
1.
Letter from S. J. Collins (NRC) to G. A. Trevors (NPPD). dated U
April 30, 1990, Transmittal of Inspection Report 90 15, 2.
Letter from G. A. Trevors (NPPD) to S. J. Collins (NRC), dated May 30,1990, NPFD Response to Inspection Report 50 298/90 15.
3.
Letter from S. J. Collins (NRC) to G. A. Trevors (NPPD), dated September 17, 1990.
4.
Letter from G. A. Trevors (NPPD) to NRC, drced October 12, 1990.
Gentlemen:
This letter is written in response to your letters dated April 30, 1990, and September 17, 1990, concerning 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 VIDIATION Failure to Include ASME Class 3 Nonintegral Component Suonorts in the ISI Procram Technical Specification 4.6 G for Cooper Nuclear Station states, in part, that inservice inspection of ASME Code Class 1, 2, and 3 components 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-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 (which is each inspection interval).
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U.S. Nuclear Regulatory Commission November 15, 1990 Page 2 Contrary to the above, Class 3 nonintegral component supports from within the boundary of each system specified in Table IWD 25001 were not included in the first and second 10 year ISI Program for VT 3 visual examinations.
Reason for Violation Since the issuance of Inspection Report 9015, there have been several discussions between the NRC and NPPD concerning the interpretation of ASME Section XI code requirements for inspecting Class 3 component supports. This issue has been further complicated by the apparent ambiguity of the exemption criteria of the code for Class 3 component supports. Cooper Nuclear Station's current 10 year ISI teoection interval is based on the 1980 Edition Winter 1981 Addenda of Section XI.
The NRC's interpretation of the code differs from NPPD's in the area of the selection process for supports to be examined.
Due to the complexity of the code requirements, NPPD unde a good faith effort to obtain clarification by submitting two inquiry questions to the ASME Section XI Code Committee at its quarterly meeting in Nashville, Tennessee-on May 14, 1990.
These inquiry questions and the Code Committee replies, which vere submitted in Reference 2, supported NPPD's original conclusion.
Af ter further tcview of this issue, including re evaluation of all available information, the District has again concluded that there may not have been a violation of NRC requirements, since NPPD's interpretation of the code did not violate the intent of ASME Section XI or Technical Specification 4.6.C; It is NPPD's understanding from Reference 3 that the NRC intends to submit inquiry questions to the ASME Section XI Code Committee meeting in December,1990 to further clarify its position.
NPPD supports this action and is willing to assist in developtrent of additional inquiry questions to further clarify the intent of the code concerning examination requirements for Class 3 component supports.
Corrective Stens Which Have Been Taken and Results Achieved At this time, the District is not yet convinced that a violation existed. However, result of our re evaluation of the CNS ISI Program selection criteria for as a supports, certain Class 3 component supports associated with integral attachments were added to the CNS ISI Program.
The addition of these originally exempted supports is based upon using an "and" in lieu of an "or" requirement in the District's interpretation of IWD 1220,2(a) and (b).
These supports and their associated integral attachments were inspected during the 1990 Refueling Outage and all were found to be satisfactory.
Corrective Stens Which Will Be Taken to Avoid Further Violations As a result of our extensive re-evaluation of code requirements in response to this Notice of Violation, NPPD considers it prudent to further supplement the CNS ISI Program for component supports (beyond ASME code requirements).
This augmented inspection program will balance the CNS ISI Program with the addition of VT-3/4 examination of selected component supports (including their associated integral or nonintegral attachments) of the safety related service water and reactor equipment cooling systems.
Furthermore, a representative sample of supports associated with nonintegral attachments will be added to the augmented inspection program for non exempt portions of Class 3 piping.
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i U.S,. Nuclocr R;gulctory Crmmission 4
'Nov2tbar 15, 1990 Page 3 This action is consistent with current CNS management philosophy that a representative sample of safety related supports should be routinely inspected, regardless of code requir ments.
Date 3Appn Full Comr'iiance Vill Be Achieved l
All program enhancements mantioned herein will be included in an augmented inspection program by the completion of the 1991 Refueling Outage. The District is of the opinion that a violation of hRC requirements may not have occurred.
The December 1990 code inquiry should clarify this position, If not, a supplement to i
this response will be issued addressing all remaining outstanding issues.
Please contact me if you have any questions or require additional information.
Sincerely, reVors Senior Staff Advisor Nuclear Power Group CAT:GEH:sa ec:
Regional Administrator r
U.S. NRC - Region IV NRC Resident Inspector Cooper Nuclear Station I
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