IR 05000285/1987014

Ack Receipt of 870729 & 0807 Responses to Violations Noted in Insp Rept 50-285/87-14 & Notice of Violation . Implementation of Corrective Actions Will Be Reviewed During Future Insp

ML20237G384
Person / Time
Site:	Fort Calhoun
Issue date:	08/14/1987
From:	Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Andrews R OMAHA PUBLIC POWER DISTRICT
References
NUDOCS 8708240070
Download: ML20237G384 (2)

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, In Reply Refer To:

Docket: '50-285/87-14

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L N& \ b W Omaha Public Power District

, ATTN: R.:L.'Andrews, Division Manager-Nuclear Production-1623 Harney Street u Omaha, Nebraska 68102  ;

Gentlemen:

' Thank you. for your letters of July 29, 1987, and August 7, 1987, in response to our letter and Notice of Violation dated June 29, 1987. We have reviewed your reply 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 maintained.

Sincerely,

.. e,.; :d by:

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'J. E. Gagliardo, Chief Reactor Projects Branch cc:

W. G. Gates, Manager Fort Calhoun Station P. O. Box 399 Fort Calhoun, Nebraska 68023 Harry H. Voigt. Esq.

LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Avenue, NW

' Washingt.a, D. C. 20036 Kansas Radiation Control Program Director Nebraska Radiation Control Program Director ES RP RSB RPB RIV:RSB/E LGilbert:gb RJIreand DRH er y/#/87 f/)(/87 4 /p /87 TFWestermang(dEGagliardo jf/ //87 / /87 k[2gg $

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-RPB RRI R.D. Martin, RA RPSB SectionChief(RPB/B) . MIS System RIV File DRSP RSTS Operator RSB Project Inspector, RPB -D. Weiss, RM/ALF R. Hall T. Bournia, NRR Project Manager L. Gilbert Section Chief (RSB/ES)

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Omaha Public Power District 3 ] g2 g g 3 1 1623 Harney Omaha. Nebraska 68102 '

402/536 4000 s i ,

July 29, 1987 JA. 3188I i LIC-87-551 J

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Mr. J. E. Gagliardo, Chief Reactor Projects Branch U. S. Nuclear Regulatory Commission l Region IV l 611 Ryan Plaza Drive, Suite 1000 j l Arlington, Texas 76011 '

References: 1. Docket No. 50-285 l 2. Letter NRC (J. E. Gagliardo) to OPPD (R. L. Andrews) dated l June 29, 1987  !

Dear Mr. Gagliardo:

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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.

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Sincerely, j

l 4V h d R. L. Andrews  !

/ Division Manager Nuclear Production RLA:rge Attachment l J

c: LeBoeuf, Lamb, Leiby & MacRae l 1333 New Hampshire Ave., N.W- l

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Washington, DC 20036 i Mr. R. D. Martin, Regional Administrator Mr. P. H. Harrell, NRC Senior Resident Inspector -

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Attachment

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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

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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 j that a source side penetrameters be used for radiographic examination of the i I

weld repairs to the girth and longitudinal welds in the emergency feedwater storage tank.

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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 Response 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 size 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 placeme'nt should have been utilized.

2. Corrrective Steps Which Have Been Tank and the Results Achieved WhenthisdiscrepancywasdisclosedtoOPPD,actionwastakento 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 c-were also done by using source side penetrameters.

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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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Omaha Public Power District 1623 Harney Omaha. Nebraska 68102-2247 402/536 4000 August 7, 1987 '~~

LIC-87-571 Mll@

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Reactor Projects Branch U.S. fluclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, Tx. 76011 References: 1. Docket No. 50-285 2. Letter NRC (J. E. Gagliardo) to OPPD (R. L. Andrews) dated June 29, 1987 3. Letter OPPD (R. L. Andrews) to NRC (J. E. Gagliardo) dated July 29, 1987 (LIC-87-551)

Dear Mr. Gagliardo:

SUBJECT: Supplement to OPPD's Response to Inspection Report 50-285/87-14 Reference 2 identified one violation involving failure to follow procedure for radiographic techniques. Reference 3 provided Omaha Public Power District's response to the violation. OPPD received comments from your staff on August 5, l 1987. As a consequence of these comments, please find attached our revised response. Changes are identified by a bar in the right margin. If you have any questionc, please contact us.

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1. 2akad R. L. Andrews Division Manager Nuclear Production RLA/me cc: LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Ave., N.W.

Washington, DC 20036 R. D. Martin, NRC Regional Administrator P. H. Harrell, NRC Senior Resident Inspector

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Attachment 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 Response l 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.8.2, 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 0 PPD as "the inability to gain reasonable access". Considering the size 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. Corrective Steps Which Have Been Taken 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 also done by using source side penetrameters.

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3. Corrective Steps Wh;ch Will be Taken to Avoid Further Violations Radiography at the Fort Calhoun Station is performed by specialized j vendors, with oversight provided by 0 PPD Quality Control and Health Physics personnel. The procedure which provides guidance to QC inspectors for their oversight of radiographic activitins will be revised to include

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additional information to ensure that applicable code requirements are satisfied. i 4. Date When full Como11ance Will be Achieved I

The procedure revision will be implemented by September 1, 1987. If any (

radiography is required prior to that date, special attention will be j devoted to verifying that all applicable code requirements are met. 1

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