ML20247G173
| ML20247G173 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 03/31/1989 |
| From: | Morris K OMAHA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| LIC-89-298, NUDOCS 8904040149 | |
| Download: ML20247G173 (7) | |
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Omaha Public Power District 1623 Harney Omaha. Nebraska 68102-2247 402/536-4000 March 31, 1989 LIC-89-298 3
U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station P1-137 Washington, DC 20555
References:
1.
Docket No. 50-285 2.
Letter from NRC (L. J. Callan) to OPPD (K. J. Morris) dated February 17, 1989 3.
Safety Analysis for Operability,89-006 (Rev. 1), dated February 23, 1989 Gentlemen:
SUBJECT:
Response to Notice of Violation - NRC Inspection Report 50-285/89-08 I
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 2.201.
I With respect to the instances of inaccurate information being transmitted to the l
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 concluded.
If you have further questions concerning this matter, please contact me or members of my staff.
Sincerely, K. J. M rris Division Manager Nuclear Operations l
KJM/jak g904o4o149 890331 l
PDR ADOCK 05000285 PDC Attachment a
c: LeBoeuf, Lamb, Leiby & MacRae R. D. Martin, NRC Regional Administrator 7
P. D. Milano, NRC Project Manager
- I P. H. Harrell, NRC Senior Resident Inspector uno w nen g t g oppununau
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RESPONSE TO NOTICE OF VIOLATION l
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 information.
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 Reauirernents 1.
Criterion XVI of 10 CFR Part 50 and the licensee's approved quality assurance program require that conditions adverse to quality, such as, deficiencies, defective material, and nonconformists are promptly identified and corrected.
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 ocrmissible 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, jl 1988.
This is a Severity Level IV violation.
(Supplement I) (285/8908-01)
OPPD Response 1.
Admission or Denial of tM Alleaed Violation OPPD admits the violation occurred as stated.
2.
Reason for the Violation. if Admitted The reason for the violation war due to focusing or, ensuring the welds involved in the modification were operable and the concentration on the 10 CFR 21 evaluation.
This effort distracted the plant personnel from reviewing the additional problem of poor radiograph quality.
- 3. Corrective Steos 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
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-Il0A (1987)
Pressurizer Spray Nozzle and Auxiliary Spray Pipe MR-FC-84-188 (1987)
Pressurizer Spray Valve Replacement 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 Side 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 review.
OPPD QC will have the final responsibility for determining the acceptability of radiographs and welds with respect to quality, technique, and weld discontinuities.
With regard to the four welds which were cited in this violation, a Safety Analysis for Operation (SA0) was 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 concerns.
4.
Corrective Steps 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 Inspections. This procedure contains a radiography procedure and a checklist which requires that safety relatu radiography will be reviewed by a Leve? II/III RT inspector to ensure that the film quality complies with the applicae code.
OPPD will continue to employ the services of a Level II/III RT inspector.
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With respect to QC role interpretations, a training session will be held for QC personnel for further instruction on reporting non-conforming conditions.
This training will be conducted by April 30, 1989.
5.
Date When Full Comoliance Will be Achieved Radiographs that are found not to be in compliance with the applicable code per QC's review mentioned in section 3 will be reradiographed to obtain the required quality during the 1990 refueling outage. OPPD will be in compliance after this radiography has been redone during the 1990 outage.
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2.
10 CFR Part 50.9 requires that information provided to the Commission by a licensee shall be complete and accurate.
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 review 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 identified which did not meet Code requirements for technique and quality.
This is a Severity Level IV violation.
(Supplement I) (285/8908-02)
OPPD REPSONSE 1.
Admission or Denial of the Alleaed Violation OPPD admits the violation occurred as stated.
2.
Reason for the Violation. if Admitted The response to Deviation 285/8831-02 stated that the results 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 incorrect.
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 OSAR.
3.
Corrective Steps That Have Been Taken and the Results Achieved The response to item 2 of Deviation 285/8831-02 has been revised and is included as Attachment 1.
OPPD is very concerned about instances of inaccurate information being transmitted to the NRC. To preclude this problem, management has communicated to Production Engineering Department personnel via memorandum the importance and responsibility for verification of accurate information.
4.
Corrective Steps 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 N0D-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 N0D-QP-9 which asks the following:
"Does the attached make reference to or utilize inform.
on/ evaluations provided by any group not involved in its writing?
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If so, have yfu 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 violation, from being provided to the Commission.
This form change is expected to be approved by May 1, 1989.
5.
Date When Full Compliance Will be Achieved OPPD will be in full compliance on May 1,1989.
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ATTACHMENT 2
- 2.
- Corrective Steos Which Have Been Taken and the Results Achieved A further review was conducted by 0 PPD personnel ~ and resulted in identifying other girth welds where the same condition existed.
OPPD's procedure for the evaluation of radiographs has been revised to include checks to verify correlation between initial and subsequent radiographs of the same weld areas.
OPPD, assisted by qualified and certified contractor personnel, conducted a review of the EFWST radiography done during the 1987 refueling outage and 1
concluded that the NDE contractor committed Code violations. OPPD is not presently utilizing this contractor for radiography work.
4 A review was conducted of the radiography done by this contractnr 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 out?ge. The results of this review showed that the quality of radiography associated 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 quality.
Action taken to correct the det..iencies with technique and quality of these radiographs are identified on the response to violation A of Inspection Report 89-08.
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