IR 05000285/1989008

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-285/89-08

ML20244B788
Person / Time
Site:	Fort Calhoun
Issue date:	04/07/1989
From:	Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Morris K OMAHA PUBLIC POWER DISTRICT
References
NUDOCS 8904190409
Download: ML20244B788 (2)

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  ::In Reply Refer To*          a
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Omaha.Public' Power 1 District ATTN: Kenneth J; Morris, Division Manager

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n2 --Nuclear Operations " 1623 Harney Street .

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  ' Omaha, Nebraska '68102
             ,.1 Gentlemen:        ..

L Thank' you for you'rz letter of: March. 31 989',1in' response to our ' letter -

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and Notice'of Violation dated February!17 1989. .We have reviewed your reply

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  - and find it responsive to the concerns raised in'our) Notice of- Violation. 'We-will' review _ the implementation'of your corrective' actions during a future inspection to' determine that full. compliance has been achieved and will be'-      .
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maintaine .r .

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Sincerely, .

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          ~ Original Sigacd By L, J. Callan

! L. J. Callan, Director t Division of Reactor Projects cc: . . . Fort Calhoun Station

  ' ATTN: : W. - G. , Gates . . Manager -

P.O.- Box 399' [; Fort:Calhoun, Nebraska 68023 Harry H.'Voigt, Es .

  ; LeBoeuf ' Lamb,-Leiby & MacRae l

1333.New Hampshire Avenue, NW I Washington,-D.C. 20036 Nebraska' Radiation Control Program Director-E g RIV:R C:MQPS g 9:DRS M D PA LGilbert/cjg- .IBarnes '

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RSTS Operator Project Engineer, DRP/B _

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L- . Omaha PulJlic Power District r

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1623 Harney Omaha. Nebraska 68102-2247 '

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L 1 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station P1-137  ; Washington, DC 20555 ' References: Docket No. 50-285 Letter from NRC (L. J. Callan) to OPPD (K. J. Morris) dated February 17, 1989 Safety Analysis for Operability, 89-006 (Rev. 1), dated February 23, 1989 I Gentlemen: SUBJECT: Response to Notice of Violation - NRC Inspection Report 50-285/89-08 Omaha Public Power District (0 PPD) received the subject inspection report. The violations involved failure to satisfy 10 CFR Part 50 requirements. A two week extension was requested in order to obtain more information with respect to the violations. Enclosed please find OPPD's response to these items in accordance with 10 CFR Part 2.20 With respect to the instances of inaccurate information being transmitted to the NRC, OPPD is currently reviewing its NRC submittal process in order to identify any deficient areas and make appropriate changes. You will be advised on this specific item as the OPPD review is conclude If you have further questions concerning this matter, please contact me or members of my staf

Sincerely, D

    &  b K. J. M ris N     Division Manager D     Nuclear Operations
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M KJM/jak b , y Attachment

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O , i c: LeBoe.uf.. Lamb,,Leiby &.MacRae

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RE D. Martin', NRC Regional' Administrator P. D. Milano, NRC Project Manager . P. H. Harrell, NRC Senior Resident Inspector

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 '.*.      Attachment 1   !

l L ' RESPONSE TO NOTICE OF VIOLATION During an NRC inspection conducted on February 6-10, 1989, violations of NRC requirements were identified. The violations involved failure to provide appropriate corrective action and failure to provide accurate informatio In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1988), the violations are listed below: Failure to Satisfy 10 CFR Part 50 Requirements Criterion XVI of 10. CFR Part 50 and the licensee's approved quality I assurance program require that conditions adverse to quality, such as, l deficiencies, defective material, and nonconformists are promptly l identified and corrected.

I Contrary to the above, corrective actions were not taken in regard to radiographs of pressurizer spray piping welds (i.e., Modification MR-FC-82-110, Welds F3A and FW3BR), that were identified by Operations Support Analysis Report (0SAR) No. 88-53 as not meeting ASME Code requirements with respect to weld penetration and/or permissible film density variations. In addition, corrective actions were not taken in regard to unacceptable film density variations in radiographs for Modifications MR-FC-82-110, Weld F5 and FC-84-188, Weld F3E, which were identified by Quality Control in Memorandum 88-QC-035 dated October 25, 198 This is a Severity Level IV violatio (Supplement I) (285/8908-01) OPPD Response Admission or Denial of the Alleaed Violation  ! OPPD admits the violation occurred as state . Reason for the Violation, if Admitted

    .The reason for the violation was due to focusing on ensuring the welds involved in the modification were operable and the concentration on the 10 CFR 21 evaluation. This effort distracted the plant perscnnel from reviewing the additional problem of poor radiograph qualit . Corrective Steps That Have Been Taken and the Results Achieved Ebasco was commissioned in October, 1988 to review radiography associated with the seven modifications listed in OSAR 88-53. This list of Page 1
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modifications represents safety related radiography performed by PSI ,

  (excluding FW-19) back to and including the.1983 outage and one modification installed in 1981. These modifications are as follows:

MR-FC-82-110 (1987) Pressurizer Spray. Nozzle and Auxiliary Spray Pipe MR-FC-82-110A. (1987) Pressurizer Spray Nozzle and Auxiliary Spray' Pipe MR-FC-84-188 (1987) ' Pressurizer Spray Valve Replacemen MR-FC-83-064 (1984) Pressurizer Mini-Spray Valve Replacement MR-FC-79-165 (1983) long Term Cooling ECCS MR-FC-82-123 (1983) Preparation of Spare Penetration E-11 for 'use ; during the 1983 Reactor Vessel Exam MR-FC-81-085 (1981) Drainage of CCW Heat Exchanger Raw Water Sid : As a corrective action recommended by Deficiency Report.FCl-89-038,-this review was expanded-to include a weld by weld description of each modification to identify radiography which may not comply with.the applicable code requirements for quality and technique. OPPD reviewed related documentation to ensure that information from referenced correspondence was included in this expanded review.- The written report

  .from Ebasco was-submitted'.to OPPD on March 27, 1989. OPPD QC Level II/III is currently conducting a Quality verification following Ebasco's revie OPPD QC will have the final responsibility for determining.the
  ' acceptability of radiographs and welds with respect to quality, technique, i and weld discontinuitie '

'" With.. regard to the four welds which were cited in this violation,.a Safety

  : Analysis -for Operation (SA0) was l performed (ref. 3) to address operability concerns. This SA0 concluded.that even though the technique and film quality were not in compliance with code requirements,.the welds do not present operability concern '4'. Corrective'Steos That Will be Taken to Avoid Further Violations With respect to the radiography being're-reviewed, film that is found not to be in compliance with the applicable code will be reradiographed in order to obtain the required quality and technique. Appropriate tracking documents will be written for all film requiring reradiography. During the 1988 refueling outage, OPPD QC employed the services of a Level III RT inspector who reviewed radiography performed during the outage to ensure that film quality was in compliance with the applicable code. OPPD QC will continue to review radiography performed in the future to ensure compliance with QDP-20, Conduct of QC Inspection This procedure contains a radiography procedure and a checklist which requires that safety related radiography will be reviewed by a Level II/III RT inspector to ensure that I the film quality complies with the applicable code. OPPD will continue to employ the services of a Level II/III RT inspecto Page 2

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conditions. : This training will be- conducted by April: 30,198 . Date When Full Comoliance Will be Achieved it ' h diographs thht:are found not to be.in compliance with the applicable code '

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per-QC's: review mentioned in section 3 will belreradiographed to obtain the:

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required quality during the 1990 refueling outage. OPPD will be in compliance.after th.is radiography has been redone during the.1990. outage.

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 ; CFR Part 50.9 requires that~information provided to the Commission by a

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licensee shall be complete andLaccurat . Contrary to the above, the licensee's response to NRC. Report No. 88-31 for Deviation 285/8831-02 was inaccurate, in that,'the response stated that

  . - results of the -reviaw of modifications installed in-the.1987 outage 'showed that the radiographs and techniques used were of acceptable quality. The review as documented in OSAR No. 88-53 reports.that radiographs were

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identified which did.not meet Code requirements for technique and qualit This-is a Severity Level IV violatio (Supplement.I) (285/8908-02) P'

 .0 PPD REPSONSE Admi!,sion or Denial of the Alleaed Violation OPPD admits the violation occurred as state . Reason 'for the' Violation. if Admitted The response to Deviation 285/8831-02 stated that the res lts of the review of modifications installed in the 1987 outage showed that the radiographs and techniques used were of acceptable quality and that they were significantly better than those from the work on tank FW-19. This was partially incorrec As stated in OSAR 88-53, both Ebasco and QC indicated

, that the quality of radiography associated with the modifications was much higher than that for the FW-19 tank radiography. However, it was not stated that the radiographs and techniques used were of acceptable quality. The preparer of the Response to Deviation 285/8831-02 improperly summarized the OSAR's contents and the lead engineer from the group which prepared the OSAR did not verify that the wording of the actual response was consistent with the conclusions of the OSA . Corrective Steos That Have Been Taken and the Results Achieved t The response to item 2 of Deviation 285/8831-02 has been revised and is included as Attachment ~

  '0 PPD is very concerned about instances of inaccurate information being transmitted to the NRC. To preclude this problem, management ha communicated to Production Engineering' Department personnel via memorandum the importance and responsibility for verification of accurate informatio . Corrective Steos That Will be Taken to Avoid Further Violations In addition to the above communique, a form change has been initiated to Nuclear Operations Division Quality Procedure N00-QP-9 " Processing of NRC, INPO, NUMARC, DEC, DOE and EPA Correspondence and Other Pertinent Licensing Documents" to ensure that groups which may have performed evaluations (EEARs,0SARs,etc.) substantiate that the response has been reviewed for completeness and accuracy. This will be accomplished by adding a question on Appendix E (Certification of Accuracy, Form FC-1077) of NOD-QP-9 which asks the following: "Does the attached make reference to or utilize information/ evaluations provided by any group not involved in its writing?

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Ifiso, have'y2u required those groups to review the attached for' completeness and: accuracy?" This will-provide a more thorough review of, the response and prevent'. inaccurate information,'as cited.in this

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violation, from being provided to the. commission. This form change is v-expected to be approved by May 1, 198 , Date When Full Compliance Will be Achieved

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OPPD(will be. in full compliance on May- 1,.1989.

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ATTACHMENT 2

  " $2rrective Steos Which Have Been Taken-and the Results Achieved
  ' A further review was conducted by OPPD personnel and resulted-in
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identifying other girth welds where the same condition existe OPPD's' procedure for the evaluation of radiographs 'has1been revised to-include checks-to verify correlation between initial = and subsequent radiographs of-the -same weld area OPPD,. assisted by qualified and. certified-contractor personnel, conducted a review of the EFWST radiography done during the 1987 refueling outage and concluded that the NDE contractor committed Code violations. OPPD is-not presently utilizing this contractor for radiography wor A review was conducted of the radiography done by this-contractor for-modifications installed during the 1987, 1985, 1984-and 1983 refueling outages and of_ the radiography of other repair work performed during the 1987 refueling outage. The results of this review showed that the qualit of radiography essociated with the modifications was much higher than that for the FW-19 tank radiography. However, the- applicable code was not adhered to in all cases with regard to technique and film qualit Action taken'to correct the deficiencies with technique and quality of these radiographs are identified in the response to. violation A of ; Inspection Report 89-0 ' s

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