ML20045H188
| ML20045H188 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 07/07/1993 |
| From: | Hampton J DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9307190188 | |
| Download: ML20045H188 (3) | |
Text
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Oconee Nudeat5de nce11esident POIku109 (h03}%531990fisce Sene< h, SC2%79 (803)!GS3564 Fax i
DUKE POWER July 7, 1993 U.S.
Nuclear Regulatory Commission Attention:
Document Control Desk Washington, DC 20555
Subject:
Oconee Nuclear Site Docket Nos. 50-269, -270, -287 Inspection Report 50-269, -270, -287/93-15 Reply to Notice of Violation
Dear Sir:
By letter dated June 10, 1993 the NRC. Issued a Notice of Violation as described in Inspection Report No. 50-269/93-15, 50-270/93-15, and 50-287/93-15.
Pursuant to the provision of 10 CFR 2.201, I am submitting a written response to the violation identified in the above Inspection Report.
Very truly yours, l
J.
W.
Hampton cc:
Mr.
S.
D.
Ebneter, Regional Administrator U.
S.
Nuclear Regulatory Commission, Region II Mr.
L.
A.
Wiens, Project Manager Office of Nuclear Reactor Regulation Mr.
P.
E.
Harmon Senior Resident Inspector Oconee Nuclear Site 9307190188 930707 T
PDR ADOCK 05000269 a i
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p Violation 269,270,287/93-15-01, severity Level IV 10 CFR 50, Appendix B, Criterion V requires activities affecting quality to be accomplished in accordance with procedures...; USA Standard B31.7-69, Section B-1-130, requires that radiographs be examined and interpreted to assure compliance with code and the applicable radiographic procedure.
This standard also requires that welds exhibiting unacceptable defects be repaired.
Radiographic procedure NDE-10, Rev.
18, paragraph 9.2, requires that when weld repairs are made, the repair number and the letter "R",
appear on the radiographic film and paragraph 19.1 requires that interpretation of radiographs shall include verification of compliance to all the requirements of the procedure and the evaluation of all discontinuities.
Contrary to the above, on May 14, 1993, the licensee was in violation of these procedural / code requirements in that, rejectable indications on radiographs of safety related welds had gone undetected; weld repairs had not been documented on the radiographic film; and fabrication-related indications, present in the radiographs, had not been documented on the appropriate record, which rendered the record (s) incomplete and inaccurate.
RESPONSE
1.
The reason for the violation, or if contested, the basis for disputing the violation:
The flim in question displayed an indication on weld number 2LP100-09 which appeared to be a surf ace indication, but could not be verified.
This resulted in a weld repair.
In addition, the radiographers inadvertently failed to place the weld repair numbers on the ID of the radiographic film.
It is not a code requirement to document non-relevant indications on the reader sheet or to put the repair number on the film, although both are good practices and are normally done in our program.
2.
The corrective steps that have been taken and the results achieved.
All of the radiographs and reader sheets in question were checked for completeness and accuracy; necessary corrections were made to ensure compliance.
The indications in question were re-verified as acceptable surface indications with the exception of the indication on weld station 3-0 on weld 2LP100-09.
This area was ground and re-welded as a repair.
The indication on weld station 1-2 on weld number 2LP96-15 was verified as an acceptable surface indication but was lightly filed off and reshot.
All radiographs and documentation in question were re-evaluated and determined to be acceptable.
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NRC Violation 93-15-01.
Pa'ge Two Refresher training was provided to the radiographers on May 19, 1993. The training included information on documentation, film review, film identification and IQI identification.
In addition, a Quality Improvement Team was established to review the violations to look for solutions on future practices.
3.
The corrective steps that will be taken to avoid further violations:
The corrective actions listed in Section 2 should prevent future violations.
4.
The date when full compliance will be achieved:
Duke Power Company is in full compliance.
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