ML19332G146

Responds to Violations Noted in Insp Rept 50-382/89-32. Corrective Actions:Util Will Continue to Perform Comprehensive Exam of Reactor Vessel Nuts

ML19332G146
Person / Time
Site:	Waterford
Issue date:	12/14/1989
From:	Burski R LOUISIANA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
W3P89-2157, NUDOCS 8912200217
Download: ML19332G146 (5)

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317 Baronno Street Id . ""~4 '

P. O. Box 60340 '

F New Oneans, LA 70160 0340 '

t - Tel. 504 595 2805

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R. F. Burski Nuclear Safety & Regulatory Affairs-

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C.,> ' December;14', 1989 m

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.U.S. Nuclear Regulatory Commission.

U", ATTN: ' Document Control Desk- ,

'SH Washington, D.C.-20555 1

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I Subjecti Waterford.3.SES'

' Docket No. 382.

,' . License No.: NPF-38.

)i NRC Inspection, Report 89-32

!.. 4 Gentlemen: 1 e

In'accordance vith?10 CFR Part 2.201, Louisiana Power.& Light hereby

. submits in Attachment l'the response' to the violation identified in

l Appendix A of,the subject. inspection report.

L If you.have-any questions concerning this response, please contact

~L.W.: Laugh 11nL at' (504) 464-3499.- ,

Very truly'yours, i

5 y aNlC RFB/DMU/ssf.

Attachment

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1cc t '. Messrs. R.D. Martin, NRC Region IV F.J. Hebdon, NRC-NRR D.L. Wiggin*on, NRC-NRR E.L. Blake

.. F ' W.M. Stevenson

-NRC Resident Inspectors Office l

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W3P89-2157 z* 1 Page 1-of 3-l ATTACHMENT 1-i LP&L RESPONSE TO THE VIOLATION IDENTIFIED IN APPENDIX A 0F INSPECTION REPORT 89 p VIOLATION NO. 8932-01 Failure of ISI Examinations ~To Comply With Procedure and Code Requirements

' Criterion V of Appendix B to 10 CFR Part 50 and the licensee's. approved l quality, assurance program description require that activities affecting_

r ' quality shall be accomplished in accordance with documented procedures.

Paragraph 6.4 in Procedure WTR-ISI-70, and Article T-761<in Section V of i

, the 'ASME Code, require that magnetic particle examinations be conducted in of at least two dirsctions.

Contrary to the above, the NRC inspector found that the 18 reactor vessel i nuts examined.during the last outage on May 2, 1988, were examined in one I l direction only.

This is a Severity Level IV violation.

RESPONSE q LP&L-does not believe that the situation addressed in Violation 8932-01 i constitutes a' failure of ISI examinations to comply with procedure and code l EL- ~ requirements.- ,

i On Mayf2, 1988, during the second refueling outage, 18 reactor vessel j closure-head nuts were examined by magnetic particle (MT) in-accordance '

with Waterford 3's 10 year inservice inspection program. An MT examination vas performed on the inner diameter (ID) and outer' diameter (OD) of each

. nut. The'MT examination of the nut OD was successfully performed in two i

' directions.

The MT examination of the nut ID was however, performed in only one 1 direction. Due to the size of the MT yoke and the inner diameter of the nut, the Level II MT examiner determined the yoke.could not be properly positioned inside the. nut to perform the second direction perpendicular to the first. This limitation was documented on the reactor vessel nut examination data sheet and concurred with by the Westinghouse Level 11 examiner's supervisor, LP&L's Level III Inspector and the Authorized Nuclear Inservice Inspector:(ANII). It is this examination that the NRC contends is a violation of procedure and code requirements.

The notice of violation states that Paragraph 6.4 in Procedure WTR-ISI-70, ,

Magnetic Particle Examinations for Waterford Unit #3, and Article T-761 in ASME Section V, require that magnetic particle examinations be conducted in at least two directions. The violation, however, fails to note that paragraph 5.1 of this procedure also states that " Examination of the 4

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• * * *l3P89-2157 Page 2 of 3 required surface shall be to the maximum extent practical. Any area which precludes 100% coverage shall be recorded on Limitation to Examination (Welds) Form or Limitation to Examination (General) Form." Therefore, areas not accessible for the required examination shall be documented as  ;

such. i NRC Inspection Report 89-32 identified the fact that reactor vessel nut acceptance criteria have not yet been established by ASME Section XI Table  !

IWB-2500-1, Category B-G-1, Item B6.10. However, what both the Inspection Report and violation failed to note was that Code Item B6.10 has not yet established an examination requirement either. It is this Code requirement 4 I

and the associated figure that will identify the specific area (s) of the nut that shall be examined. Without this Code requirement, there is nothing that specifies which areas of the nut should be examined.

in view of this, it would be perfectly acceptable to perform an MT t examination in two directions on only the outside diameter (OD) of the nut.

This would fulfill the literal requirements of ASME Section V, Section XI and WTR-ISI-70. However, in keeping with the spirit of the code, it has  !

been LP&L's practice to perform as thorough an examination of the nut as the examiner determines possible. In this case, after performing an examination in one direction on the nut I.D., the examiner determined a credible examination 90' to the first could not be performed due to nut geometry.

In accordance with Paragraph 5.1 of WTR-ISI-70, this limitation was documented on the reactor vessel nut examination data sheet. Although the procedure states this should be recorded on the " Limitation to Examination (General) Form", when questioned on this in the NRC exit meeting of October i 20, 1989, the NRC inspector stated the recording of this limitation on the i data sheet was acceptable, i

The inability to perform all or part of a required examination due to component configuration or proximity is not a new or unique situation. The NRC recognizes interf erences will occur and that' all component exataination

-requirements can not be met. A relief request process has been established i to address these situations. However, with no examination requirements specified in Section XI, this option is not appropriate. Therefore, limitations encountered when performing a reactor vessel nut ID examination will be addressed as already done; in accordance with Procedure WTR-ISI-70, Paragraph 5.1.

To summarize, LP&L contends no violation of the Code or procedure has i occurred. The MT examiner determined a 2 directional examination was not f possible and documented such per procedure. Because the Code does not provide specific examination requirements and acceptance criteria, there can be no violation of the Code.

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d4 LP&L wil1~continueLt'o perform the'most comprehensive examination of the l l. ri Mreactor! vessel: nuts possible.a When ASME'prcvides examination. requirements" .

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- 'and-acceptanceicriteria. LP&L~will make the necessary provisions to ensure' -

@ itotal" compliance. Should full-compliance with these requirements not bel practicalc or.possible,: a relief request- will be prepared- and submitted to

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l Bas'ed'on.the information-provided above, LP&L requests that Niciation:

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8932 be-re-evaluated.

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