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Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-298/89-17
	ML20246N205
Person / Time
Site:	Cooper
Issue date:	07/10/1989
From:	Milhoan J; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Trevors G; NEBRASKA PUBLIC POWER DISTRICT
References
	NUDOCS 8907190316
	Download: ML20246N205 (2)
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JUL 01989

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.In Rep 1.y Refer To:

) LDocket: :50-298/89-17.' ,

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L Nebraska Public Power' District ~

. ATTN: . George A.' Trevors

,iDivision Manager - Nuclear. Support

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t.P.O.. Box 499

' Columbus. Nebraska' 68602-0499

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Gentlemen:, ^

Thank"youLfor your letter ofiJune 15, 1989, in. response to ourcletter'and

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!: Notice'of Violationfdated'May'17. 1989. We he'fe reviewed your reply land. find

h it' res'ponsive t.o thA concehns ra.ised in our Notice of Violation. We will

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review the ; implementation of your. corrective actions during a future inspection..

tb, determine'thatifull'compliailce has been achieved and will be maintained.

< Sincerely,

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7%se GaspJ

James L.'M11hoan, Director

Division'of. Reactor Projects

cc: .

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Cooper Nuclear' Station

ATTN: . Guy Horn, Division Manager

~ offhuclear Operations

P.O. Box 98~

Brownville, Nebraska 68321

. Kansas Radiation Control Program Director

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h Nebraska Radiation Control Program Director

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CNSS8'97279

June 15, 1989 ~ gg

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U.S. Nuclear Regulatory Commission < ..- - -

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Attention:. Document Control Desk

Washington, DC 20555

Subject: NPPD Response to Notice of Violation - NRC' Inspection Report 89-17

Gentlemen:

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This letter is written in response to.your letter dated May 17, 1989,

transmitting Inspection Report 50-298/89-17. Therein you indicated that

certain of our activities were in violation of NRC requirements.

Following is a statement of the violations and.our response in accordance with

10CFR2.201.

STATEMENT OF VIOLATION

A. Failure of the ISI Program to Identify All Applicable Supports and Welds

Criterion V of Appendix B to 10CFR Part 50 and the licensee's approved

quality assurance program description., require that activities affecting

quality shall be accomplished in accordance with documented instructions.

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Paragraph 4.2.1 of the ISI program for ASME classes 1, 2, and 3

components, Revision 3, dated March 3, 1985, for the Cooper Nuclear-

Station requires that the ISI program provide an item listing.

' Contrary to the abov e , the NRC inspector found that the ISI program

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failed to identify, in it. 11 sting, nine suppotts (RFil-FC-ll2, 59A, 58,

.56, 54, 54A, 53; and Rl!F-FB-59 and 55) and 15 welds (numbers llP10-52-

through 66) that should be listed in the IF1 Program.

Reason for the Violation

The reason for the violation was 1) lack of attention to detail by the

contractor who prepared Revision 3 of the ISI program and 2) subsequent

inadequate review of the ISI program by the District prior to its

acceptance.

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U.S.' Nuclear.Regulat'ory Commission.-

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F A review of the project files' for Revision l3.to the ISI.. program revealed :

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that isometric drawing'2623-3.was;indeed contained'on the original list

' of- isometric drawings bounded by ASME Section. XI. Furthermore, .it was

observed that . this ' isometric drawing was flaggedas "not' presently

available" '(for ' review) . As - such, . it appears that the necessary

follow-up actions to enable' review of isometric drawing 2623-3 were not'~

completed due to 'the reasons stated above, ~ resulting in the omissions

cited in the Notice of Violation.

One other omission. (RFil-FC-.112) not contained on isometric drawing 2623-3

is considered'a. random omission which is also attributable to lack of'

attention to detail-and inadequate program review.

. Nebraska:Public Power District admits to the violation as stated.

Corrective Steps Which Have Been Taken and the Results Achieved

-A detailed review of approximately 80 isometric-drawings was performed:to.

determine. the extent. of welds missing. f rom the -ISI . program. 'The results

of' this review identified 18 -code class one and 30 code class two welds

which were l shown on . the' applicable isometric drawings, but were not-

listed in the ISI program as required. However, despite these omissions,

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t.he minimum percentage of completed exams required'by ASME Section.X1 had

been fulfilled. Therefore, an operability concern did not exist.

Corrective Steps Which Will he Taken to Avoid Further Violations

All'omitted welds and currently identified components will be added to

the ISI program through the issuance of.an addendum by August, 1989. .A

detailed review will be completed by September, 1989,.to determine the

extent of additional component supports missing from the ISI program.

Any omissions identified by this review will be added to the ISI program

through the issuance of an addendum by October, 1989. 'l

Additional staf f bar been added to the CNS Engineering Department to

provf.de increased overview of ongoing programs. The District feels that

the edditional staffing is sufficient to prevent recurrence.

Date When Full Compliance Will Be Achieved

All necessary IFI program changes will be enmpleted by October 1989.

B. Welding Controls

Criterion IX of Appendix-B to 10CFR Part 50 states, in part, "Heasures

shall be established to assure that special processes, including welding.

....are controlled and accomplished by qualified personnel using

qualified procedures ...." This is implemented by the Ifcensee's

approved Ouality Assurance plan.

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! * U.S. Nuclear Regulatory Commission

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Paragraph QW-200 in Article 11 of Section IX to the ASME Code states that

changes may be made in the nonessential variables to suit. production

requirements provided such changes are documented either in an amendment

to the original welding procedure specification (WPS) or a new WPS.

Contrary to the above, changes in non-essential variables specified in a

WPS (amperage and voltage) had been made during production welding

without documenting such changes.

Reason for the Violation

The reason for the violation is less than adequate procedures and failure

of personnel to follow procedures. This is evident considering the !

As such, ;

corrective actions that have been implemented to date.

corrective actfon emphasis to prevent recurrence is being placed

primarily on procedure and training enhancements. Nebraska Public Power

District admits to the violation as stated. #

Corrective Steps Which llave Been Taken and the Hesults Achieved

Statements of corrective actions were previously transmitted to the

Nuclear Regulatory Commission in NPPD's letter (CNSS895719) da t ar'

May 8, 1989, G. R. Ilorn (Division Manager of Nuclear Operations; o

Li J. Callan (Director, Division of Reactor Projects). These correct.ive

actions are reiterated as follows:

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11 A programmatic change has been implemented to ensure that each

welder is cognizant of pertinent welding procedure requirements.

, Prior to performing a given welding procedure, and each day

thereafter when welding activities are in progress, the welder must

read the welding procedure and acknowledge (by signature) his

understanding of its requirements. This methodology will be

follower' until the Weld Checklist changes described in Item 2,

beb:, can be implemented. In addition, each welder has received

co mseline, regarding the necessity of adhering to all welding

procedure requirements, especially in the need to either meet the !

non-essential variables specified, or obtain apptovn1 for and j

document any devintions.

2. a. A very experienced and knowledgeable Welding Engineer

(consultant) has been retained to provide a third party review

of the existing welding procedures to ensure their adequacy and

make the procedures more user friendly,

b. In addition, more detail is being added to the welding process

control document, the Weld Checklist, regarding the parameters

which are under the welder's control. The Weld Checklist is

also being made more user friendly to facilitate welder

adherence to the specified requirements.

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U.S. Nuclear Regulatory Commission

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3. To further ensure welder adherence to welding procedure require-

ments, the depth and frequency of the independent teview achieved by

our- Quality Assurance and Quality Control personnel has been

increased. The pertinent Q.A. surveillance checklist is being used

-to document verification of both essential and non-essential

variables with special attention to the electrode amperage being

used. Several-of these surveillance are to be performed each week

to observe both station welders and contractor welders. The

' described level of indeptadent review will be continued for the

duration of the outage.

Supplements to- these corrective actions were subsequently

transmitted to the Nuclear Regulatory Commission in NPPD's letter

(CNSS890248) dated May 25, 1989, G.'R. Horn (Division Manager of

Nuclear Operations) to J. L. Milhoan (Director, Division of Reactor

Proj ects) . These supplementary corrective actions are reiterated,

in part, as follows:

a. Selecting frequently used Welding Procedure Specifications

(WPSs) that required revision to clarify the requisite

variables. Using the CNS temporary < procedure change mechanism,

any required changes were made prior to furthar use of the

procedure. Certain procedures, which are not frequently used,

have not yet been revised, but they will be changed prior to l

use. In the longer term,-the temporary procedure changes will

be made permanent.

b. Prior to performing welding activities, each welder will be

issued a controlled manual which contains up-to-date copies of

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the welding procedures which he is qualified for and expected

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to use. The welders will continue to review the appropriate

WPS prior to use, and daily thereaf ter, whera welding. These

meaiures will continue until they can be superceded by

permanent, equivalent programmatic changen.

c. A correlation has been made regarding welding ma(hine amperage

and the welding machine dial settlags. Charts are posted on

each welding machine. These chart s will be signed and dated to

verify their authenticity. The welders have been instructed to

vefer to these charts when setting np the machine to ensure

that the amperage is within the Limitations of the Welding

Procedure Specification. For WPSs which require voltage to be

mc.ni t ored , the capability to monitor this paraneter will be

provided.

An evaluation will be performed to determine the most viable.

option for monitoring these parameters in the future, In the j

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interim, a monthly PM will be implemented to perform the

aforementioned correlation on active welding machines. The

results will then be trended to determine the optimum PM

frequency.

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d, For'i.he remainder of'.the Spring '1989_ Outage, a dedicated roving .

' Welding Supervisor.was added to each' shift, in addition to the

. supervisory overview present1' :y Lin place. : 1This -~ supervisor -

overviewed all'_ welding-activities occurring on his shift.

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o. Regarding.-the depth of.the independent Quality: Assurance review-

q of welding activities two. surveillance checklists have been

developed. . ,0ne checklist . is designed to physically observe

welding:in progress and ' verify: compliance with, essentini . and

'IU non-essential variables. -~The'other' checklist.is designed'to-

assess welder's knowledge'of controllable welding parameters by.

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direct interview of'the welder.

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Th'e surveillance wi11T he coordinated to be conducted on: each'

newly qualified welder within'-the subsequent; week'sl schedule-

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following his/her qualification. Following completion. of L the

initial surveillance as described above, surveillance will-be a

scheduled and conducted such that at least. 20% of currently)

qualified' welders;will be evaluated each week.- Such surve11-'

lances will emphasize'in progress safety-related welding to the-

greatest extent practicable.

' Selection of welders to be evaluated shall - be. such . that

different welders will.be chosen'each week,Jto - the' greatest i

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extent practicable._ It is intended that the weekly surveil-

lance process will continue until such ' tinic as the. level of'

welding activity is significantly reduc,ed -(outage' completion),

or procedural provisions are . approved for, use which will

necessitate re-evaluation of the surveillance function.

The District believes that these corrective actions adequately-address

the concerns identified herein.

pptrective Steps Which Wil), Be Taken to Avoid Further Violations o

In addition'to the corrective steps identified.above, the District will

retain the aforementioned Welding Engineer (coneultant) to perform a

comprehensive, independent review of the CNS Welding ' Program, . including

all procedures and field implementation practices. It is expected that

further enhancements to the CNE Welding Program will be in.plemented as a

D result of the contractor's recommewlations. Furthermore, adequacy of i

personnel training in the areas of AFME Section IX uiethodology and

procedure compliance will be reviewed to ident.ify any weaknesses that may.

exists.

Date When Full Compliance Will Be Achieved ;

All corrective actions will be completed by October, 1989. )

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II:' you . have .' any fquestions'. regarding this _ response, please .' contact' me L 'o r

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iG;cR.;' Horn at the siteL.-

Sincerely ~',L

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'. . revors-

Division Manager-

Nuclent Support.-

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cc: ;S.' Nuclear-Regulatory Commission

Region 11V-

p;. ._ Arlington, Texas ,

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NRCEResidentl Inspector

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ML20246N205

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