ML20246N205
| 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) | |
See also: IR 05000298/1989017
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JUL - 01989
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.In Rep 1.y Refer To:
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LDocket: :50-298/89-17.'
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Nebraska Public Power' District ~
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. 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:,
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- 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
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it' res'ponsive t.o thA concehns ra.ised in our Notice of Violation. We will
review the ; implementation of your. corrective actions during a future inspection..
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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
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Cooper Nuclear' Station
ATTN: . Guy Horn, Division Manager
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offhuclear Operations
P.O. Box 98~
Brownville, Nebraska 68321
. Kansas Radiation Control Program Director
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Nebraska Radiation Control Program Director
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CNSS8'97279
June 15, 1989 ~
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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
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.
Paragraph 4.2.1 of the ISI program for ASME classes
1,
2,
and 3
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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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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.
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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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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
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corrective actions that have been implemented to date.
As such,
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;
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Li J. Callan (Director, Division of Reactor Projects).
These correct.ive
actions are reiterated as follows:
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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
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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
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non-essential variables specified, or obtain apptovn1 for and
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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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June 15, 1989
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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
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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
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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
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interim, a monthly PM will be implemented to perform the
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aforementioned correlation on active welding machines.
The
results will then be trended to determine the optimum PM
frequency.
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'.: U.S;i Nuc1 Ear [ Regulatory, Commission
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For'i.he remainder of'.the Spring '1989_ Outage, a dedicated roving .
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' Welding Supervisor.was added to each' shift, in addition to the
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supervisory overview present1' :y Lin place. : 1This -~ supervisor -
overviewed all'_ welding-activities occurring on his shift.
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Regarding.-the depth of.the independent Quality: Assurance review-
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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
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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
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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
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different welders will.be chosen'each week,Jto - the' greatest
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extent practicable._ It is intended that the weekly surveil-
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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
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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
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result of the contractor's recommewlations.
Furthermore, adequacy of
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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 ' r
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iG;cR.;' Horn at the siteL.-
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Sincerely ~',L
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revors-
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- Division Manager-
- Nuclent Support.-
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- S.' Nuclear-Regulatory Commission
Region 11V-
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NRCEResidentl Inspector
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