ML20234D301
| ML20234D301 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 09/14/1987 |
| From: | Trevors G NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| CNSS877424, NUDOCS 8709220046 | |
| Download: ML20234D301 (2) | |
Text
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m CNSS877424 September 14, 1987 Nuclear Regulatory Commission Document Control Desk Washington, D.C.
20555
Subject:
NPOD Response to Inspection Report 50-298/87-20 Gentlemen:
This letter is written in response to your letter dated August 20, 1987, transmitting Inspection Report 50-298/87-20.
Therein you indicated that one of our activities was in violation of NRC requirements.
Following is a statement of our violation and our response in accordance with 10CFR2.201.
STATEMENT OF VIOLATION Failure to Perform Liquid Penetrant Examinations Section 50.55(a) of 10CFR Part 50 requires that, throughout the service life of the plant, components which are classified as ASME Code Class 1 shall meet the requirements set forth in Section XI of the ASME Boiler and Pressure Vessel Code.
Article IWA-4000 of Section XI requires that, following installation of a replacement component by welding, the required construction code nondestructive examination requirements shall be met in addition to those examinations required for preservice inspection.
Contrary to the above, two final welds were not liquid penetrant examined as required by the construction code following installation of an ASME Code Class 1 replacement component, valve RWCU-M015, in accordance with Maintenance Work Request No. 86-4914. A liquid penetrant examination had been performed on the two welds and met the preservice inspection requirements; however, the acceptance criteria for preservice inspection is less stringent than the construction code.
This is a Severity Level V violation.
(Supplement I)(298/8720-03)
Reason for Violation The violation is correct as stated.
The root cause of the violation is attributed to inadequate procedural guidance in the application of ASME Section XI rules for replacement of Class 1 components by welding.
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Corrective Steps That Have Been Taken and the Results Achieved Subsequent to the occurrence and prior to the discovery of this violation, Station Procedure 0.30, "ASME Section XI, Repair /Replar.ement Program", was implemented by station management.
This new procedure uses ASME Section XI rules to develop a Repair / Replacement Plan detailing all 10CFR50 requirements for each repair / replacement to the pressure retaining boundary of applicable Code Class 1, 2, and 3 components and their supports. As such, this procedure provides the necessary link between applicable ASME Section XI rules and the station corrective maintenance procedures to ensure proper application of code requirements in the field.
Corrective Steps Which Will Be Taken to Prevent Further Violations NPPD is of the opinion that Procedure 0.30, "ASME Section XI, Repair / Replacement Program", currently provides adequate guidelines to ensure that similar violations do not occur.
Additionally, the subject installation welds for valve RWCU-M015 will be re-examined in accordance with the appropriate construction code during a refueling outage scheduled to begin in February, 1988. No further corrective action is necessary.
Date When Full Compliance Will Be Achieved j
Full compidance will be achieved by April 1, 1988.
G. A.# revors T
Division Manager of Nuclear Support GAT:SSF:ss cc:
U.S. NRC Regional Office, Region IV NRC Resident Inspector Cooper Nuclear Station
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