ML20237B122

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-285/98-07 on 980415-24

ML20237B122
Person / Time
Site:	Fort Calhoun
Issue date:	08/14/1998
From:	Powers D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Gambhir S OMAHA PUBLIC POWER DISTRICT
References
50-285-98-07, 50-285-98-7, NUDOCS 9808180060
Download: ML20237B122 (4)

See also: IR 05000285/1998007

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UNITED STATES

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NUCLEAR REGULATORY COMMISSION

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August.14, 1998

S. K. Gambhir, Division Manager

Engineering & Operations Support

Omaha Public Power District

Fort Calhoun Station FC-2-4 Adm.

P.O. Box 399

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Hwy. 75 - Noith of Fort Calhoun

! ort Calhoun, Nebraska 68023-0399

SUBJECT:

NRC INSPECTION REPORT 50-285/98-07

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Thank you for your letter of August 4,1998, in response to our May 21,1998, letter and

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Notice of Violation concerning the failure to submit relief requests for Code Class welds that did

~ not receive 100 percent full examination coverage during the first and second 10-year in service

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inspection intervals. 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.

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Sincerely,

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Dr. Dale A. Powers, Chief

Maintenance Branch

Division of Reactor Safety

Docket No.:

50-285

License No.: DPR-40

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9808180060 900814

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Omaha Public Power District

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' James W. Tills, Manager

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Omaha Public Power District

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. P.O. Box 399

Hwy. 75 - North of Fort Calhoun

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Fort Calhoun, Nebraska 68023-0399

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James W. Chase, Manager

Fort Calhoun Station

P.O. Box 399

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- Perry D. Robinson, Esq.

Winston & Strawn

1400 L. Street, N.W.

Washington, D.C. 20005-3502

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Washington County Board of Supervisors

Blair, Nebraska 68008

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Cheryl Rogers, LLRW Program Manager

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Environmental Protection Section

Nebraska Departrnent of Health

301 Centennial Mall, South

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P.O. Box 95007:

Lincoln, Nebraska 68509-5007

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August 4,1998

LIC-98-0094

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U.S. Nuclear Regulatory Commission

ATTN: Document Control Desk

Mail Station PI-137

Washington,DC 20555

References:

1.

Docket No. 50-285

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2.

Letter from NRC (Dr. D. A. Powers) to OPPD (S. K. Gambhir) dated May 21,

1998

3.

Letter from OPPD (S. K. Gambhir) to NRC (Document Control Desk) dated June

22,1998 (LIC-98-00082)

SUBJECT:

NRC Inspection Report No. 50-285/98-07, Reply to a Notice of Violation (REVISED)

The subject report transmitted a Notice of Violation (NOV) resulting from an NRC inspection conducted .

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April 15-24,1998 at the Fort Calhoun Station (FCS). Omaha Public Power District's (OPPD) response,

submitted by Reference 3, has been revised as requested by the inspector for clarification of the review

given to the second interval ISI exam results. This revision elso restores details in Section 3 of the

response which were inadvertently omitted. Attached is the Omaha Public Power District (OPPD)

response in its entirety, which supersedes the previous response submitted by Reference 3.

In view of the historical nature of this violation and other reasons, as described in the attached response,

OPPD is not planning to submit any relief request or exemption from the requirements of 10 CFR 59.55a(g) for the first and second 120 month intervals of the Inservice Inspection (ISI) program.

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If you should have any questions, please contact me.

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S. K. Gambhir

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Division Manager

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Engineering and Operations Support

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Attviment

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E. W. Merschoff, NRC Regional Administrator, Region IV

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L. R. Wharton, NRC Project Manager

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W. C. Walker, NRC Senior Resident Inspector

Winston and Strawn

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Employment with Equal Opratunity

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Attachment

LIC-98-0094

Page1

REPLY TO A NOTICE OF VIOLATION

Omaha Public Power District

Docket No.: 50-285

Fort Calhoun Station

License No.: DPR-40

During an NRC inspection conducted on April 15-24,1998, one violation of NRC

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requirements was identified. In accordance with the " General Statement of Policy and

Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below:

Technical Specification 3.3(1)a requires that the inservice inspection of ASME Code Class

.1, Class 2, and Class 3 components be performed in accordance with Section XI of the

ASME Boller and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50, Section 50.55(g)(sic), except where relief has been granted by the Commission pursuant

to 10 CFR 50.55a(g)(6)(l)(sic).

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The ASME Code,Section XI(1980 Edition Winter 1980 addenda and 1989 Edition)

requires,in part, that components shall be examined and tested as specified in Tables IWB-

2500-1,IWC-2500-1 and IWF-2500-1.

10 CFR 50.55a(g)(5)(iii) requires that "if the licensee has determined that conformance

with certain code requirements is impractical for its facility, the licensee shall notify the

Commission and submit, as specified in 50.4,information to support the determ! nations."

10 CFR 50.55a(g)(5)(iv) requires that "where an examination requirement by the code or

addenda is determined to be impractical by the licensee and is not included in the revised

inservice inspection program as permitted by paragraph (g)(4) of this section, the basis for

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this determination must be demonstrated to the satisfaction of the Commission no later

that 12 months after the expiration of the initial 120-month period of operation and each

subsequent 120-month period of operation during which the examination is deterrr.ined to

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be impractical."

10 CFR 50.55a(g)(6)(1)(sic) states, in part, that "the Commission will evaluate

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determinations under paragraph (g)(5) of this section that code requirements are

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impractical. The Commission may grant such relief and may impose such alternative

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requirements as it determines is authorized."

Contrary to 10 CFR 50.55a(g)(5)(iv), the inspectors identified that the licensee had not

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submitted in 1984 and 1994 relief requests for those Code Class welds that did not receive

100 percent full examination coverage during the first and second 10-year inservice

inspection intervals.

This is a Severity Level IV violation (Supplement 1)(50-285/9807-01).

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Attaclunent

LIC-98-0094

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.QEPE Response

The Notice of Violation referred to 's CFR 50.55(g) and 10 CFR 50.55a(g)(6)(1). The actual

code sections are 10 CFR 50.55a(g) and 10 CFR 50.55a(g)(6)(i).

1.

Reason for the Violation

The cause of this condition is OPPD's long-standing interpretation of the requirements of 10

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CFR 50.55a(g)(5)(iv).

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Paragraph 10 CFR 50.55a(g)(5)(iv) was interpreted in the FCS Inservice Inspection (ISI)

Program to require relief for impractical examinations ofinaccessible components only if the

cause ofinaccessibility resulted from a hardware change that occurred after the preservice exam

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or after the last completed ten year examination interval, or was determined to be impractical due

to ALARA or cost considerations rather than technological barriers. This interpretation is based

on OPPD's understanding of 10 CFR 50.55a(g)(i) which states, "for a boiling or pressurized

water cooled nuclear power facility whose constmetion permit was issued prior to January 1,

1971, components (including supports) must meet the requirements of paragraphs 10 CFR 50.55a (g)(4) and (5) of this section to the extent practical." OPPD interpreted this section to

mean that incomplete exams caused by obstructions inherent in the original design were

impractical to fully examine and were exempted because FCS's construction permit was issued

prior to 1971.

2.

Corrective Steps Taken and Results Achieved

At the beginning of the third ten year ISI exam interval, OPPD adopted a policy to note the

achieved exam coverage on each ISI exam report. This policy made it possible to promptly and

accurately identify the limited exams performed thus far in the third ten-year interval and the

extent of coverage achieved. OPPD component testing personnel reviewed the ISI examinations

performed thus far in FCS's third ten-year examination interval to identify the limited exams.

FCS is half way through the third ten-year interval (i.e. three of six refueling outages scheduled

for the third ten-year interval have been completed.) It was detennined that 18 limited exams

have been performed so far in this interval. A listing of these exams including the percent

coverage was prepared and given to the NRC Inspector at the exit meeting for the NRC ISI

inspection on April 24,1998.

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If the 18 limited exams reported above are reviewed using the definition of" essentially 100%

coverage" per the guidance given in NRC Information Notice 96-32, only eight of the 18 limited

exams fall below the " essentially 100% coverage" definition. The guidance referred to in

In ; c' nation Notice 96-32 is for the Implementation of 10 CFR 50.55a(g)(6)(ii)(A), Augmented

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Examination of reactor vessel, June 5,1996 and Code Case N-460.

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I,1C-98-0094

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OPPD reviewed the exam coverage for the scheduled / performed ISI exams in the present (third)

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interval at FCS and determined that the amount ofweld volume missed due to inaccessible

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exams is estimated to be about 2% of the weld volume required by the code. OPPD has

performed volumetric examination of some unscheduled welds based on industry findings and

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has occasionally scheduled weld exams in excess of the code requirement. These additional

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welds could be considered to compensate (in part) for some of the missed weld volume. As

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discussed below, exam limitations experienced in ine third ten-year interval are expected to be

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representative of the limitations experienced in the first and second intervals. A detailed review

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of the volumetric ISI exam tesults for FCS's recond ten-year interval, and to date in the third ten-

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year interval, showed that no indications have been identified that required repair. The review of

the volumetric ISI exam results for FCS's second ten-year interval did not include a

determination of percent coverage. A curse.y review of the first ten year interval abo identified

no repairable indications. OPPD has not installed any non-code repairs and the RCS integrity

test, performed at the conclusion of the 1998 refueling outage, has not identified any weld

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failures. Based on this information OPPD has concluded that the exam voicme missed due to

limited exam coverage is not statistically significant and that there is reasonable assurance that

the FCS safety system piping is sot.nd and capable of performing its design basis function.

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3.

Corrective Steps That Will Be Taken To Avoid Further Violations

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OPPD plans to continue the policy of noting the cause and percentage oflimited exam coverage

on each ISI exam report as the exams are performed in accordance with the examination schedule

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for the third ten-year interval. Further, OPPD plans to identify, by September 3,1998, on the

NIS-1 Report, any limited exams and the percent coverage achieved on these limited exams so

that the most current data on FCS's exam coverage will be available to the NRC.

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Regarding those limited exams that were performed during the first and seccmd ten-year

intervals, a significant ef fort and resource commitment would be required to do the research

required to develop the specific examination details which were provided for the third ten-year

inspection interval. However, althougb there are differences in components selected for

examination in each of the first three FCS ten-year ISI exam intervals as detailed in the

respective ISI Program Plans, most of the exams identified thus far in the third ten-year interval

as having limited coverage are vessel, nozzle, safe end, branch connection, etc., exams that have

also been mandatory examinations in the first and second ten-year intervals. Thus, it is expected

that the list oflimited exams for the third ten year interval would be generally the same as lists of

limited exams for the first and seccad ten-year intervals.

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Attachment

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' fter evaluating cost and ALARA conccrns, FCS does not consider further investigation of the

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first and'second interval weld coverag: to be a pmdent use of resources. Therefore, OPPD does

not plan to prepare relief requests for the limited volumetric exam coverage during the first and

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Esecond ten-year inspection intervals. FCS will continue to identify and track limited coverage

exams throughout the third ten-year ISI exam interval and will request relief as required under

the Code.

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.The date when full compliance will be achieved

There are no safety related technical issues associated viith the ISI examinations for the first and

second intervals a., discussed above. FCS is currently in compliance for the third ten year -

. interval since the time limit for requesting relief has not yet expired. Since we are now aware of

'the intent of the regulation, we will remain in compliance.

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