ML20235M392

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-298/87-20

ML20235M392
Person / Time
Site:	Cooper
Issue date:	10/01/1987
From:	Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Trevors G NEBRASKA PUBLIC POWER DISTRICT
References
NUDOCS 8710060173
Download: ML20235M392 (1)

See also: IR 05000298/1987020

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Docket:- 50-298/87-20

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Nebraska. Public Power District

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ATTN: George A. Trevors

Division Manager - Nuclear Support

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P. O. Box 499

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Columbus, NE

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Gentlemen:

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.Thank you for your letter of September 14, 1987, in response to our letter

and Notice of Violation dated August 20, 1987. We have reviewed your reply and

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find it responsive to the concerns raised in our Notice of Violation. We will

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review the implementation of your corrective actions during a future inspection

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to determine that full compliance has been achieved and will be maintained.

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Sincerely,

Original Si;ned by:

R, E. HALL

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J. E. Gagliardo, Chief

Reactor Projects Branch

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Guy Horn, Division Manager

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Cooper Nuclear Station

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COOPER NUCLEAR STATION

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September 14, 1987

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Nuclear Regulatory Commission

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Washington, D.C.

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Subject: NPPD 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, valse 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

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construction code.

This is a Severity Level V violation.

(Supplement I)(298/8720-03)

Reason for Violation

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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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Saptamber 14, 1987

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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 / Replacement Program", was

implemented by. station management.

This new procedure uses ASME Section XI

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rules to develop a Repair / Replacement Plan detailin'g 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

Full compliance will be achieved by April 1, 1988.

G. A. Trevors

Division Manager of

Nuclear Support

GAT:SSF:ss

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cc:

U.S. NRC

Regional Office, Region IV

NRC Resident Inspector

Cooper Nuclear Station

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NRC Distribution

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