ML20236M182
| ML20236M182 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 07/29/1987 |
| From: | Andrews R OMAHA PUBLIC POWER DISTRICT |
| To: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| LIC-87-551, NUDOCS 8708100502 | |
| Download: ML20236M182 (3) | |
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a 3 g'g-Q pig Omaha Public Power District i
5t 1623 Harney Omaha, Nebraska 68102 402/536 4000 3
j, July 29, 1987 l
JLt.31198I j }1 LIC-87-551 l
.l Mr. J. E. Gagliardo, Chief Reactor l'rojects Branch U. S. Nuclear Regulatory Commission Region IV 61; Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011
References:
1.
Docket No. 50-285 2.
Letter NRC (J. E. Gagliardo) to OPPD (R. L. Andrews) dated June 29, 1987
Dear Mr. Gagliardo:
SUBJECT:
Inspection Report 50-285/87-14 The subject inspection report identified one violation. The violation involved failure to follow procedure for radiographic techniques.
Pursuant to the provisions of 10 CFR Part 2.201, please find attached the Omaha Public Power District's response to this violation.
Sincerely, 4V 4.Z dr.,
k R. L. Andrews
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' Division Manager Nuclear Production RLis: rge Attachment c:
LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Ava., N.W.
W shington, DC 20036 Mr. R. D. Martin, Regional Administrator Mr. P. H. Harrell, NRC Senior Resident Inspector kh S$$
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.w Attachment l
During an NRC inspection' conducted May 5-8, 1987, a violation of NRC require-ments was identified. The violation involved failure to follow procedure for radiographic techniques.
In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions", 10 CFR Part 2, Appendix C (1987),
the violation is listed below:
Violation Criterion V of Appendix B to 10 CFR Part 50 requires that activities affecting quality be prescribed by and accomplished in accordance with appropriate instructions, procedures and drawings.
Professional Services Industries (PSI) Procedure 81-102, Revision 3, requires that a source side penetrameters be used for radiographic examination of the weld repairs to the girth and longitudinal welds in the emergency feedwater storage tank.
Contrary to the above, PSI radiographer the weld repairs to two girth welds in the emergency feedwater storage tank, identified as welds G1 and G2, using film side penetrameters.
This is a Severity Level IV violation.
(Supplement I) (285/8714-01)
OPPD's Resoonse 1.
Reason for the Violation, if Admitted The PSI radiographic examination procedure did in fact allow for film side placement of the penetrameters (Step IV.B.2, Paragraph 2).
The violation stems from a misinterpretation of the word " inaccessibility".
In the context of the examinations that took place on the emergency feedwater storage tank, the word " inaccessibility" was interpreted by OPPD as "the inability to gain reasonable access".
Considering the ize of the tank, placement of the penetrameters on the inside (source side) of the tank was impractical and inefficient as it would have required scaffolding and major interruptions in the weld repair work. The Commission has interpreted " inaccessibility" to mean " impossible to gain access".
In referencing ASME Section V Code Interpretation No. V-83-02, it is apparent that the Commission's rendering is correct; however, it should be noted that OPPD did not fail to follow the radiographic procedure, but that in determining between source side versus film side placement of the penetrameters, source side placement should have been utilized.
2.
Corrrective SteDs Which Have Been Tank and the Results Achieved When this discrepancy was disclosed to OPPD, action was taken to re-radiograph girth welds G1 and G2 using source side penetrameters.
(Both the source side and film side radiography yielded equally acceptable results).
The remaining radiographic examinations conducted on the tank were alsa done by using source side penetrameters.
I A
Attachment (Continued) 3.
The Corrective Steos Which Will Be Taken to Avoid Further Violations The actions described in Item 2 above are considered adequate. No further actions are planned.
4.
The Date When Full Comoliance Will Be Achieved OPPD is presently in full compliance.
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