ML20247R195
| ML20247R195 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 05/26/1989 |
| From: | Trevors G NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CNSS897271, NUDOCS 8906070160 | |
| Download: ML20247R195 (4) | |
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- COOPER NUCLEAR STATION Nebraska Public Power. District
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1 CNSS897271-May 26,-1989 1
f U.S. Nuclear Regulatory Commission Attention: Document Control Desk' Washington, DC 20555
Subject:
NPPD Response to Notice of Violation - NRC Inspection Report No. 89-15 Gentlemen:
This letter is written in response. to your letter. dated May 1,
- 1989, transmitting Inspection. Report 50-298/89-15.
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 Criterion IX of 10CFR. Part 50 Appendix B specifies that measures shall be established to assure that welding is controlled and accomplished by qualified personnel using qualified. procedures in accordance with applicable codes and other special requirements.
Contrary to the above:
Maintenance Procedure 7.~.15 does not control the heat input within
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a.
the limits' qualified as required by ASME Section IX, 1983 Edition, for welding materit.ls requiring impact prcperties.
b.
The post-weld heat treatment specified in Maintenance Procedure 7.7.16 was not qualified by the supporting Procedures Qualification Report (PQR) as required by ASME Section IX.
c.
Radiographic examination reports, 173-98061-2 and 173-98061-5, for double wall radiography of two welder performance qualification tests recorded that the penetrameters were placed source-side inside the pipe although the radiographic procedure specified placement of the penetrameters source-side and outside the pipe.
d.
Holding ovens containing E7018 electrodes were outside the temperature range specified in Maintenance Procedure 7.7.3.2, and the temperature was not being checked daily as required by the procedure.
8906070160 890526
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The - temperature - rsnge = of ~ 150-200*F, specified --In Maintenance Procedure 7.7.3.2 for electrode holding ovent does not' comply with AWS D1.1-85, which states that E7018 electrodes shall be heated to-at leant-250*F.
REASON FOR THE VIOLATION'
-The reason for violation items "a" and "b" was inadequate review of-new procedtires for compliance to applicable codes.
As such, Maintenance Procedure 7.7.15 and 7.7.16 were not in compliance with ASME Section IX as indicated in violation items "a" and "b".
The reason for violation item ' "c" was originally believed to.be a typographical error-in.the NDE contractor's reports. However, it was later
'found that due to'an error on the part of the contract NDE technician, actual misplacement of the penetrameters had occurred with. respect to the requirements specified 'in the applicable revision of the contractor's procedure. This error was.not subsequently detected by Cooper Nuclear Station-(CNS) personnel.-
Thc. reason for violation. item "d" was inade.luate review-of new procedures for impact upon existing practices.
As such, personnel responsible for field g
implementation of new welding procedures were not fully aware of required changes.
The reason for violation item "e" was failure to identify the constraints of the more limiting code.
In lieu of AWS D1.1, CNS had conformed - to ASME Section II and previous manufacturers' recommendations for-electrode storage.
temperature. The: temperature range specified in Maintenance Procedure.7.7.3.2 adequately meets the recommendations of ASME Section II; however, the requirements of AWS D1.1 are more limiting than the recommendations of ASME Section II.
Nebraska Public Power District admits to the violation as stated.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED
'1.
Item a:
Procedural controls were iraplemented to restrict welding which requires notch toughness qualification until exiating procedures are revised to include the necessary controls for heat input.
It should be noted that no welds were made per Maintenance Procedure 7.7.15 to materials which require impact testing.
2.
Item b:
A change to Maintenance Procedure 7.7.16 has been 1nplemented to remove the non-qualified post-veld heat treatment.
This measure will en:ure that processes specified will be qualified by the supporting PQR.
It should be noted that no welds were made per Maintenance Procedurt 7.7.16 which required post-weld treatment.
a
.:U.S. Muc1 car Regulatory Commission M:y 26, 1989 Page 3 3.
Item c:
An audit of the responsible NDE technician's work has been initiated by the NDE contractor's Quality Assurance Department.
The results of this audit will indicate if other of the NDE technician's inspection practices are in error and require further review.
If other substantial ocviations are noted in the technician's practices, the authorization for the technician to continue to perform NDE at CNS will be revoked.
A review of the welder qualification records has been performed and welders who have been qualified by the erroneous method indicated in violation item "c" have been identified; their authorization to perform the affected welds has been revoked.
This measure precludes further production of the affected welds by personnel whose qualifications are in question.
The appropriate shop supervisors have been directed to identify affected production welds, if'any, which were made by.those personnel whose qualifications are in question.
Either the appropriate welders will be re-qualified, or NDE will be performed for affected welds to verify weld acceptability, if practical.
If welders are not available for re-qualification or if NDE is not possible, the welds will be removed and performed by qualified personnel.
Those actions listed hereia which have not yet been completed will be completed prior to' startup from the 1989 Outage.
4.
Item d:
Maintenance personnel who are responsible for issuing electrodes for field use have been instructed to check and log the holding oven temperature daily.
This measure, combined with the increased Q.C. effort in the welding area, will ensure compliance with Maintenance Procedure 7.7.3.2.
Maintenance Procedure 7.7.3.2 will be chanFed to reflect these instructions prior to startup from the 1989 Outage.
3.
Item e:
A change to Maintenance Procedure 7.7.3.2 has been implemented to increase the holding oven temperature range to 255'F to 295'F.
This measure, combined with actions taken in response to violation item "d" and recently implemented Q.C. checks, will ensure procedural compliance to AWS D1.1-85 and to manufacturer's recommendations.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS 1.
A Nonconformance Report (NCR) has been initiated for the mispositioned penetrameters as described in violation item "c".
This action provides the means for CNS to document the root cause for this deviation and to document and track those corrective actions which will be taken to preclude recurrence.
Root cause determination and resolution of field welds (if any) will be completed prior to startup from the 1989 Outage.
Long term corrective actions which are identified as a result of the evaluation will be implemented by October, 1989.
U.S. Nucionr Rzgulatory Commission 1
- 4 May 26,.1989 Page 4 2.
Contract welding engineering services have been obtained from a qualified vendor t3 review the CNS welding program to verify procedural adequacy, code compliance, and field implementation.
In addition, the contractor will. provide welding program enhancements which will f acilitate better control over the welding program by CNS personnel responsible for welding program overview.
The scheduled completion date for this action is October, 1989.
3.
In concert with the contracted Welding Engineer's review, recommended welding procedure additioas, deletions, and changes will be implemented.
The scheduled completion date for this action is October, 1989.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The corrective steps noted will be implemented on the dates specified herein, with full compliance achieved by October, 1989.
If you have any questions regarding this response, please contact G. R. Horn at the site or me.
Sincerely, G. A. Trevors Division Manager of Nuclear Support GAT:sa cc:
U.S. Nuclear Regulatory Commission Region IV Arlingtor., Texas NRC Resident Inspector Cooper Nuclear Station
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