ML20237J613
| ML20237J613 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 08/07/1987 |
| From: | Andrews R OMAHA PUBLIC POWER DISTRICT |
| To: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| LIC-87-571, NUDOCS 8708180256 | |
| Download: ML20237J613 (3) | |
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Omaha Public Power District 1623 Harnet) Omaha Nebraska 68102 2247 402/536-4000 August 7, 1987
! i LIC-87-571 h
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J. E. Gagliardo Reactor Projects Branch U.S. Nuclear 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 l
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, 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 questions, please contact us.
s Sin etwak&
R. L. Andrews Division Manager Nuclear Production RLA/me cc: LeBoeuf, Lamb, Leiby & MacRae l
1333 New Hampshire Ave., N.W.
Washington, DC 20036 R. D. Martin, NRC Regional Administrator P. H. Harrell, NRC Senior Resident Inspector 8708180256 870807
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PDR ADOCK 05000285
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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 1.
Reason for the Violation, if Admitted The PSI radiographic examination procedure did in fact a!1ow 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 l
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 ' hat 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.
o Attachment (Continued) 3.
Corrective Steps Which Will be Taken to Avoid Further Violations Radiography at the Fort Calhoun Station is performed by specialized 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 activities will be revised to includa additional information to ensure that applicable code requirements are satisfied.
4.
Date Wnen Full Compliance Will be Achieved The procedure revision will be implemented by September 1, 1987.
If any radiography is required prior to that date, special attention will be
- devoted to verifying that all applicable code requirenients are met.
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