ML20244E355

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-298/89-15

ML20244E355
Person / Time
Site:	Cooper
Issue date:	06/14/1989
From:	Mihoan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Trevors G NEBRASKA PUBLIC POWER DISTRICT
References
NUDOCS 8906200287
Download: ML20244E355 (2)

See also: IR 05000298/1989015

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Docket:~.50-298/89-15 ,

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Nebraska Public Power. District-

' ATTN: -George A.-Trevors

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Division Manager Nuclear' Support

--,. P.O. Box.499.

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. Columbus, Nebraska 68602-0499

Gentlemen:'

Thank you for.your letter of May 26, 1989, in response to our letter and

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Notice of Violation' dated May 1, 1989.. We have reviewed your reply and find.

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

review the in:plementation of your corrective actions during a future

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

maintained. ,

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Sincere

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James L. Milhoan, Director

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Division of Reactor Projects

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1 ' Cooper Nuclear Station .

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' ATTN: Guy. Horn, Division Manager

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of Nuclear Operations

P.0; Box 98

~Brownville, Nebraska 68321

Kansas Radiation Control Program Director

Nebraska Radiation Control Program Director

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COOPER NUCLEAR ST ATioN

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• Nebraska Public Power District " * * "A*c"AWs L*L^Y^ "'"

CNSS897271

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May 26, 1989

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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. Thereir. 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 abova:

a. Maintenance Procedure 7.7.15 does not control the hear input within

the limits qualified as required by ASME Section IX, 1983 Edition,

for welding materials requiring impact properties.

b. The post-weld heat treatment specified in Maintenance Prncedure 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 electrodee 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.

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I' e. The temperature range of 150-200*F, specified In Maintenance

l Procedure 7.7.3.2 for electrode holding ovens does not comply with

l AWS Dl.1-85, which states that E7018 electrodes shall be heated to

at least 250'F.

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REASON TOR THE VIOLATION

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l' The reason for violation items "a" and "b" was inadequate review of new

L procedures for compliance to applicable codes. As such, Maintenance

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Procedure 7.7.15 and 7.7.16 were net 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

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typographical error in the NDE contractor's reports. However, it was later

l 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

l- requirements specified in the applicable revision of the contractor's

! procedure. This error was not subsequently detected by Cooper Nuclear Station

(CNS) personnel.

The reason for violation item "d" was inadequate review of new procedures for

impact upon existing practices. As such, personnel responsible for field

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 DI.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 DI.1 are more limiting than the recommendations of ASME

Section II.

Nebraska Public Power Dictrict admits to the violation as stated.

CORRECTIVE STEPS WICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED

l 1. Item a: Procedural controls were implemented to restrict welding which

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requires notch toughness qualification until existing

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 implemented

to remove the non-qualified post-weld heat treatment. This

measure will ensure that processes specified will be qualified

by the supporting PQR. It should be noted that no welds were

made per Maintenance Procedure 7.7.16 which required post-weld

treatment.

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, ;M:y 26, 1989

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.3. ' Item c:' An audit of the . responsible NDE technician's work has been

inftiated by the NDE contractor'e 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 deviations 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 velder 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, wh'ch 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 herein

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 changed to reflect these instructions

prior to startup from the 1989 Outage.

5. 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 DI.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

l 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.

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y,f,..iMzy 26, 1989

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2. . Contract welding engineering services have been obtained from a qualified.

. vendor to 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 facilitate 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 k'elding Engineer's review, recommended-

welding procedure additions, deletions, and changes will be implemented.

The scheduled completion date for this action is October, 1989.

DATE LTEN 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,

b

G. A. Trevors

Division Manager of

Nuclear Support

GAT:sa

cc: . Nuclear Regulatory Commission

Region IV

Arlington, Texas

NRC Resident Inspector

Cooper Nuclear Station

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