JPN-92-068, Provides Brief Overview of Various Significant Actions & Status of Major Issues Which Led to Licensee Conclusion That Plant Ready for Restart & That People,Processes & Resources Now in Place to Maintain High Level of Safety

Provides Brief Overview of Various Significant Actions & Status of Major Issues Which Led to Licensee Conclusion That Plant Ready for Restart & That People,Processes & Resources Now in Place to Maintain High Level of Safety

ML20126H242
Person / Time
Site:	FitzPatrick
Issue date:	12/17/1992
From:	Ralph Beedle POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:	Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20126H223	List: JPN-92-068, Provides Brief Overview of Various Significant Actions & Status of Major Issues Which Led to Licensee Conclusion That Plant Ready for Restart & That People,Processes & Resources Now in Place to Maintain High Level of Safety ML20126H221
References
JPN-92-068, JPN-92-68, NUDOCS 9301050111
Download: ML20126H242 (14)

Text

,

_, iENCLOSURE"2-4-

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December 17,1992 JPN 92 068 Mr. Thomas T.- Martin Roglenal Administrator U.S. Nuclear Regulatory Commission 475 Allendate Road King of Prussia, PA 19400 i

SUBJECT:

James A. FitzPatrick Nuclear Power Plant'_

Docket No. 50 -333 fleadiness to ReMati Door Sir: ,

During the past year, the Now ork Power Authority has aggressively developed i programs and implomonted correctivo_ actions to improve the overati management, _

physica1 condition and staff capability to safely. operate the FitzPatrick plant. Since the -

start of the curront outage in November 1991; the Authority instituted management-changes, implemented hardware improvementsi and_ identifed and resolved technical:

lasues. The Authority is confident that the management, organization and physical .

condition of the plant support the restart of FitzPatrick. This letter provides a brief:

overview of the various significant actions and_tho status of major issues ~which led to the Authority's conclusion that the plant is ready for restart.

A. ORGANIZATION AND MANAGEMENT in response to Authority initiated self assessments, INPO.ovaluations and NRC ,

inspections, the- Authority developed programs designed to improvo overall management ~

t and operation of the FitzPatrick planto Initiatives included the FitzPetrick Results' c

~ -Improvement Program, tho Nuclear Generation Business Plan, and establishment of the

- Nuclear 1.cadership Team as described to the NRC in correspondence (Referenco 1) and 4 meetings. Since the implementation of these programs l the effectiveness of managem,ont oversight has improved.

j E SITE MANjGEMENT AND_COBP_ ORATE SUPPORT-In addition to measures taken for overallmanagement effhctiveness, specific :

measures have also been taken to improve the effectiveness of the on-site management team and tijo support provided to plant oporations. Examples of actions taken includo:

Creabor' of thice General Manager positions at the FitzPatrick pla61 to increase

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70'imagement focus s't the Ley functioaal areas of Operations, Maintenance, and Support Sorvices. ,

Authorization of 40 new pennanont positions to increano cupport of plant opeuttions. Apptoxirnately 90% of those positions havo boon filled to dato. This increase in staff includes an additional Reactor Operator.(RO) for each shift. Also, lho Shift Technical Advisor (STA) position has been reinstated as a separato position. Training programs aro in place to qualify individuals for the additional RO and STA positions. The romainder of the staff increasu was allocated to the Maintenanco, instrumentation & Control, and Radiological and Environmental Services departments and for additionut auxiliary operators.

Authorization of approximately 70 now engineering positions including a 34 person Site Engincoring stati reporting to the headquadors offico. The responsibilities of '

this group includo the reduction of the plant modification backlog, closcout of existing plant modifications, and accoleration of the pipe suppod evaluation program. Assignment of then responsibilities to this group allows the FitzPatrick Technical Sorvices department to focus on day-to-day plant operational issues.

Approximately 60% of those positions have boon filled.

Establishment of five new iiconsing ongineer positions for the BWR Uconsing Section (one of which is permanently stationed on sito) bringing tho total to twolvo.

Two of thoso new positions are cunontly filled including tho onsito position.

Creation of a new Nuctoar Programs Assossment Group within the Nuclear Generatico Operations and Maintenanco Division. This team will provido an independent internal assessment of plant conditions and performanco across the complete spectrum of plant and corporato suppait activitios. The organizational structuro for the Group has been ostablished and a preliminary budgot is in place..

The position of the Group Director has been filled and the recruitmont of the Group stalf in underway.

.C. PHYSICAL BEADINES.S The most comprohonsivo measure of the physical readiness of the plant is the status of tho items identified on the Authority's " Major Technical Task" list. This list has been usuct during this outage to monitor the work progross on 30 major topics requiring resolution prior to plant startup. The items are resolved with the exception of 2 and 3 which will bu completed prior to startup. The following is a I!st of the 30 major topics.

1) Seierted NRC Diagnoctic Evaluation Observations (DEOs)

2) Fire Protection Program Issues

3) Appmdix R Modificaticns / Compensatory Actions

4) Foxtwo instrument Cabinet Seismic Quatibcation

5) Operating E>:porience Hoview Program

6) . Master Equipmont list Reclassification Opernbility Assessment

7) NYPA Readiness for Hcstart Review G) Rr soWtion of Renctor Vessel Head naw Indication

9) HPCI / I1C10 Containment isotahan valves

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10) ATTS Rolated Concerns (PM program, etc.)

11) Safoty Related Pump Room Ventilation

12) Generic Letter 83 26 Audit Resolution

13) Torus Temperaturo RTD

14) ESW / EDG Retum Lino Modification

15) LPCI MOV Indepondent Power Supply EO Concorns

16) ESW SSFl Follow-up Actions

17) Control Room Annunciators

10) EDG Control Circuit Ground issues

19) Secondary Containment Solsmic Concom

20) EQ Enclosuro ACU Operability

21) Rocirculation System Pipe Supports

22) ISI Prossure Test Adverse Quality Condition Reports

23) Dual Function Containment isolation Valves

24) 10 CFR 50 Appondix J Rovlow

25) NRC Information Notico 92 35

26) SBM Switch - Operability impact

27) HGA Relay - Operability impact

20) Reactor Water Lovel Instrumentation

29) Safoty Related Functional Assessment

30) Motor Operated Valve Concems in addition, post work testing is complete to the extent possiblo and valve lineups and startup survelliances are in progress.

D FIRE PROTEGJ10B The Authority has boon actively working to resolve the firo protection issuos. On August 2,1991, the Authority mot with the NRC at the Region i Office to discuss NYPA identified deficienclos in the FitzPatrick Firo Protection Program. As a result of this mooting, the Authority issued a schedule for Short Term Fire Protection Actions to be completed prior to startup from the next refueling outago (Referenco 2) and a schedule for Long Term Fire Protection Actions to be completed after startup from the following refueling outage (Referenco 3). In responso to NRC inspections and Authority initiated re-analysis efforts, the Authority issued an updated Fire Protection Improvement Program (Reference 4) which consolidated over two hundred issues identified in various sources and provided a schedule for the completion of those itoms. The Authority has re-assessed our overall compliance with fino protection requirements and performed a new Safe-Shutdown ana!ysis. We corrected identified deficiencies and completed inspections of fire barriors. The Authority is continuing to implement and update the Fire Protection improvenmi Program and is committed to complete all outstanding items.

Organi:ntion changes have been made to further focus the Authority's efforts in the lite protection area. The new position of Firo Protection Manager has boon established with a staff dedicated to resolving fire protection issues. Resources and procedures are in place to ensuru continued compliance in the fire protection area.

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E._CADLE SEPAR ATION During the NRC Restart Assessment Team Inspection in October 1992, the NRC identiflod a potential doviation involving inadoquato separation between cables of rodundant safety divisions, la responso to this observation, tho Authority immodiately initiated field surveys to determine the extent of the problem. The field surveys indicalod the nood for a systematic approach to idontify and correct cable separation deficienclos.

As a result of those survoys, the Authority is dovoloping and imptomonting a comprohensivo program to address cablo separation issues. The Authority has also retained a consultant with sigmficant exportise in the development of such programs.

The program identifies and resolves potentially safety significant cable separation issues prior to plant restart. The program consists of developing guldolines for tho idontification of potential discrepanclos, conducting field inspections, and evaluating inspection rosults. The justification for accepting discrepancies from the FSAR critoria will bo documented in 10 CFR 50.59 Safoty Evaluations prior to restart. In addition, all necessary operability evaluations will be completed prior to restart.

EJYQBK REQUESTS During this outago, the plant Maintenance and I&C departments have completed over 3500 work requests,2200 preventativo maintenance work items, and more than 300 surveillanco tosts. Each day, now work requests are scrooned to identify thoso requiring completion prior to startup. In addition, the outstanding work toquests woro reviewed by the General Manager Maintenanco, soveral timos during this outage, to confirm the proper assignment of priority.

All modifications and maintenance activities that require post work testing will be completed prior to startup except thoso activities that must be conducted during the actual startup process. The FitzPatrick Startup Plan (see section K below) provides for holdpoints during the startup ovolution for the conduct of those activities.

GJ10BK PRACTICES in addition to completing outstunding work requost ltoms, the Authority clso improved work conduct and processes. Work was performed using good radiological practices as indicated by fewer Radiological Incident Reports (RIR's), and substantia!!y lower exposuro during reactor disassembly and reassembly activities compared to -

previous outagos. Attention to industrial safety has improved and the plant staff continuos to stress attention to detail and procedural adherenco. Improvements occurred in managoment's attention to daily operation and maintenance activities to identify items -

which require follow up, conective actions, or root cause ovaluations.

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4 R NONCONEOEMANCE_BEEOlllS During the pact year, the Fitzpatrick Quality Assuranco group has performod approximately 100 survoillancos and 30 audits, including 4 program assessmonts. Theco evaluations covered all NRC SALP performance areas and included 11 audits and 16 surveillances in tho areas of cafoty assessment and quality verification, in March,1992 all open Adverso Quality Condition Hoports (AOCRs) were reviewod and thoso requiring _

resolution prior to startup were identifiod. Beginning in April,1992 the Plant Leadership Team routinoly reviewed all OA open items that woro generatod, and added them to the' startup list as appropriato. As further assurance that all appropriato OA items aro comploted prior to startup, previously closed items were also reviewod. All Quality Assuranco audits, recommendations and AOCRs issued after January 1,1986 woro reviewed. Of the 2254 Items, only 51 required clarification or additional follow up. None of thoso 51 items requiro completion prior to startup.

l. RESULTS IMPROVEMENT PROGRAM AND STARTUP READJNESS EVALUATION The Fit 7 Patrick Results Improvement Program (RIP) is an action plan for upgrading the performance of the FitzPatrick and headquarters staff. The program identified more than 800 specific actions classified into oight root cause categorios. The Nuclear Leadership Team, comprised of the Exocutive Vico Prosident Nuclear Gonoration, the throo Nuclear Generation Vice Presidonts, and the Resident Managers of both Authority nucloar plants, routinely reviews the progress toward mooting the objectives of the FitzPatrick RIP.

The Authority's Startup Readiness Evaluation (SURE) program was lnitiated by the NLT to identify and verify acceptable resolution of issues considered to be important to the restart of the FitzPatrick plant. Tho initial assessment, conducted during the last week of

' August, reviewed the status of 22 wide ranging issues identified by the NLT. The SURE concluded that more work needed to be dono, but appropriato programs were in place to comploto this work. A summary of the Initial ovaluation was transmitted to tho NRC in Reforanco 6.

J. TECHNICALEPECIFICATIONS AND_ EXEMPTIONS The Authority and the NRC havo completed all but one formallicensing action required for stanup. The NRC has granted fivo amendments to the FitzPatrick Technical Specificatio'x which were requ red to allow plant modifications and faci!itate testing. The NRC has abo geoed six exemptions ham fire protection requirements contained in 10 CFR 50.48 and 10 CFR 50 Appendix R. These exemptions woro necessary in order to pormit FitzPetrich plant operation Some of the exemptions woro issued on a temporary basis until certain long term fire protection modifications can be completed.

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The Authority submitted and tho NRC has issuod Safoty Evaluations for Inservice Testing (IST) re!iof roquests, the results of reactor vessel head inspections, and the results of intorgranular Stress Corrosion Cracking (lGSCC) Inspections. The results of those intpoetions showod that there wero no significant changes in previously detocted flaws in the reactor coolant system pressure boundary piping and confirmed that the indication in tho vessel hea<J is not a crack.

Two liconsing actions aro required for startup. Ono is a Technical Specification amendment which will permit mode changos while an Action Statement is in effect that permits indofinito plant operation. The Authority has submittod the proposod amendment, which conforms with Gonoric Letter 87-09 and is currently under NRC review. The other is relief from an ASME Section XI requirement nocessary to repair a Reactor Water Cleanup System valve. The Authority anticipatos NRC approval prior to the scheduled startup date, in addition to those licensing actions, the Authorify has submitted the Coro -

Operating Limit Report as required by Technical Specifications. The Authority hus n!so submitted four Technical Specification amendment applications to the NRC in accordance with our commitments to the NRC staff.

K. STARTJ)f.f_L@

The Authority prepared and issued a Startup Plan (dated July 27 992) to ensure a safe and orgard:cd restart of the FitzPatrick plant. One component of the Startup Plan is the Startup Roadinoss Evaluation previously discussed in section 1. The Startup Plan also addressos the actual conduct of the startup. Several specific measures, including activo involvement of management porsonnel and the establishment of prodolined milostones, are described in the Startup Plan.

A member of the NLT will be available 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day during plant startup to act in an advisory capacity and provide an interface between sito management and the White Plains Offico, in addition, a Senior Nuclear Manager (SNM) will be assigned to each shift during plant startup until the reactor achieves a power level groator than 30 porcont of .

rated. The SNM provides assistance to the Shift Supervisor to aid in ensuring that safety and quality roccive priority over power generation. Prior to hoatup and at each of the seven predefined milestones, the Plant Leadership Toarn (PLT) will meet to receive reports from Department Managers and Supervisors. The PLT will coordinate the resolution of opon issuos and make recommendations to the Resident Managor regarding readiness to continue to the next milestone.

Another important component of the Startup Plan is a Startup Self-Assessment l- Program. Individual responsibilities, intomal reporting requirements, and an evaluation mechanism are established in the Startup Plan. The goal of the Startup Self. Assessment Program is to provide:

• Added assurance of ordorir and safe operations.

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= Additional monitoring and assessment of plant oporations, programs, and equipment.

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• An additional mechanism for the prompt identification and resolution of problems which impact operations. '

An additional mechanism for the identification u, areas that may bonorit from further -

Improvement through the Authority's Results improvement Program.

L INPO INSEECTION INPO conducted an inspection at the FitzPatrick plant in mid November and reported their results to the plant staff on November 20,1992, Tho inspection covered the functional areas of Organization and Administration, Operations, Maintenanco, Training, Radiation Protection, and Engineering Support. The Authority roviewed INPO's draft findings and has dotormined that no now issues or rostraints to startup woro identified.

INPO's written report is expected in January,1993, at which timo the Authority will review the nood for any additional actions.

M. NRC RESIART ASSESSMENT The NRC Rostart Assessment Team inspection was conducted at the FitzPatrick Plant on October 5 - 14,1992, Although the inspection results (Reference 6) supported plant restart, throo specific issues woro identified which required resolution prior to restart.

1. Control of Temporary Modifications: The inspection identified an example in which a temporary modification, in place for greater than 30 days, was not noted in the drawing controllog as roquired by Authority procedure, in addition to correcting the specific oxamplo, the Authority porformed a 100% review of all remalnlng-temporary modifications. An improvement to the controlling procodsro has been made and a wookly review is now performed to initiate a drawing (,hango in the ovent that a temporary modification extends beyond 30 days. The Authority-committed to reducing the number of temporary modifications in p. lace from over -

100 to betv/ con 44 and 62 prior to startupJ Approximately 59 temporary modifications are curmntly la place.

2. Cable Separation: This topic was previously discussed in section E.

3. Sotpoint control: in response to the NRC observation on setpoint control, the Authority conducted a mu!ti-department review of surveillance tests to determino if-setpoinln contained in procedures have sufficient margin to account for instrument -

drif t (fu:ing plant operntion. The review concluded that a total of eight proceduros required revision for sotpoint values and these revisions are complete.

The inspection also observed that temporary scaffolding erected around safoty related equipment was not in accordance with plant procedures. The Authority has sinco -

inspected scatfolding and either removed it as the associated work was completed or conected the deficiencies. Personnel have also been re-trained on adherence to the scaffolding procedure.

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Fim protectiori activitios and status of items rotated to 10 CFR 50 Appondix R will be detailod in a separato letter. Tho Authority will also submit separate correspondonco concoming the rocent review and re-evaluation of radiographs.

Based on tho extensivo management reviews of programs and correctivo actions takon, the Authority concludos that the Fit 2 Patrick plant is now ready for restart in addition, wo bellovo tilat the poopic, processos and resources are now in placo to maintain a high lovel of safety. If you have any quostions, ploaco contact Mr. J. A. Gray, Jr.

Very truly yours, AR .-J- S 4.-. K .

Ralph E, Beedlo cc: U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Mall Station P 137 Washington, D.C. 20555 Offico of the Resident inspector U.S. Nuclear Regulatory Commission P.O. Box 130 Lycoming, NY 13093 Mr. Brian C. McCabo

,. Project Directorato 1-1 l Division of Roactor Projects -- 1/Il l U.S. Nuclear Regulatory Commission L Mail Stop 14 D2 '

l Washington, DC 20555 l

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BEEEBERCES

1. NYPA lotter, H. E. Goodie to the NRC (JPN 91072) dated Docombor 30,1991,

• Proposed Technical Specification Changos to Section 6.0, Administrativo Controls."

2. NYPA lettor, R. E. Beodle to the NRC (JPN 91043) dated August 16 1991,

' Schedule for Short Terrn rire Protection Actions."

3. NYPA letter, R. E. Boedlo to the NRC (JPN-91050) dated September 13,1991, "Schodule for Long Term Firo Protection Actions."

4. NYPA letter, R. E. Beodle to the NRC (JPN-92-023) dated May 27,1992,

• Fire Protection improvement Program."

5. NYPA lettor, H. E. Beedle to the NRC (JPN-92 059) dated September 28,1992, "Roadiness Assossment."

6. USNRC lotter, C. W. Hehl to H. P. Salmon, Jr. dated November 12,1992, "NRC Restart Assessment Toam Inspection."

ENCLOSURE 3 BESOLUTION OF REMAINING TECllNICAL ISSUES There were three technical issues that developed late in the outage that required resolution prior to plant restart. These issues involve: (1) the adequacy of the relay room CO 2 IIIe suppression system and its impact on control room habitability; (2) the adequacy of separation between cables of redundant safety divisions; and (3) questions regarding the adequacy of safety-related welds and radiographs. The NRC has reviewed NYPA's corrective actions for these deficiencies and concluded that they are satisfactorily resolved for restart. Our basis for that conclusion follows.

Relay Room CO2Fire Suppression System Previously, in NRC Inspection Report 50433/92-80, the NRC identified that the design basis for the relay room CO 2fire suppression system was insufficiently documented and tested to demonstrate that the system would adequately perform its fire suppression function. In' a letter dated May 27,1992 (JPN-92-023), the New York Powe Authority (NYPA) committed to perform a CO 2discharge test in the relay room to demonstrate the system's acceptability and operability. When the discharge test was performed on November 11 1992, the test was aborted due to leakage of CO2 into the control room via a common relay room / control room supply ventilation mtake structure.

Based on the unacceptable discharge test, the relay room CO2 system was declared inoperable-and in accordance with the Technical Specifications, backup fire suppression equipment and a-continuous fire watch were established and maintained. (The relay room CO2 system is-designed to be manually initiated based on installed heat detection la the relay room and alarms in the control room.) NYPA implemented an action plan, dated December 15, 1992, that provided additional corrective and compensatory actions to enable reactor startup and i operation, The action plan items included the following:

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• The fire fighting pre-plan for the relay room was revised to provide a caution not to initiate the CO2 system without first obtaining the Shift Supervisor's permission. The l

plan was also enhanced to reflect other available manual suppression systems in the area.

• Operating Procedure, OP 55, " Control Room Ventilation and Cooling," was revised

! to provide direction to operators for the isolation of the control room ventilation system.

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• Operating Procedure OP-56, " Relay Room Ventilation and Cooling," was revised to better describe system configuration during actuation of the CO2 fire suppression system.

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• The Alarm Response Procedure was changed to ensure that prior to manual initiation of the CO 2system, control room operators are directed to carry out the actions in a new Abnormal Operating Procedure, AOP-63. AOP-63 directs that the control room ventilation system be placed in isolation, non-essential personnel be evacuated from the control room, all personnel in the relay room be evacuated (including the fire watch), and control room personnel don self-contained breathing apparatus and continue its use until habitability is verified.

• A Special Condition Tag requiring Shift Supervisor permission prior to CO 2 initiation has been posted at the remote station.

• Posted instructions (operator aid) have been placed on the Gre protection panel (in the control room) to instruct operators to don self-contained breathing apparatus prior to CO2 initiation.

• Corrective maintenance on the control room to relay room door restored it to original design basis leak tightness.

• A relay room ventilation control logic verification was completed.

• Licensed operators will be trained on all of the above procedure changes prior to startup or prior to assuming watchstanding responsibilities, and all fire brigade members will be retrained on the revised fire fighting pre-plan.

The NRC reviewed the action plan items and concluded that combined with the Technical Specifications required actions, the action plan provided an acceptable approach for system operation during reactor restart and operation. In addition, the NRC reviewed the revised procedures and the completed actions, and found them to be acceptable.

NYPA management has committed that the above corrective and compensatory actions for the relay room CO2fire suppression system will remain in effect until system modifications can be designed, installed, and tested satisfactorily, including reperformance of the discharge test.

Tentative NYPA plans include presentation of a system modification to the Plant Operations Review Committee in January 1993, and installation and testing during a suitable, subsequent reactor outage. The NRC concluded that this approach was acceptable.

Electrical Cable Srparation NRC Inspection Report 50-333/92-82, unresolved item 333/92-82-04, identified that there were numerous examples where FitzPatrick electrical control and power cables did not meet the Final Safety Analysis Report (FSAR) criterion (Section 7.1.9) for separation between electrical cables of redundant safety trains.

3 The FitzPatrick FSAR stipulates a 3 feet horizontal and 7 feet vertical separation between cables of redundant safety trains. The FSAR also lists certain acceptable deviations from those criteria. The licensee performed safety evaluations addressing the criteria under_10 CFR 50.59 and determined that changes could be made that did not constitute unreviewed safety questions.

The licensee conducted a detailed plant walkdown of 100% of the critical portions of the plant (i.e. relay room, cable spreading room, cable tunnels, battery room corridor, etc.), and -

a general walk througn of the remaining portions of the plant (i.e turbine building, radwaste building, portions of the reactor building, etc.) to identify other separation deficiencies. As a result of the inspection, many minor items were fixed (e.g., tie wrap adjustments) and-numerous cable separation deficiencies were evaluated.- Referencing certain test reports such as those from Braidwood, the licensee conducted an evaluation that concluded that all the remaining FSAR separation deviations do not represent technical sr.ecification operability questions and were acceptable. The licensee formally submitted and docketed their safety evaluation in a December 24,1992, letter to the NRC.

The NRC conducted an in plant inspection and review of the licensee's plant walkdown (identification) program. No deficiencies were identified by the NRC and we concluded that the licensee's program appeared reasonable and comprehensive. The program properly -

characterized the FSAR requirements and proved capable of identifying field deviations.

The NRC reviewed the licensee's safety evaluations and their basu documents that concluded that the remaining separation deficiencies were acceptable. The NLC concluded that the - . .

Braidwood test report results bounded the reduced separation distance acceptance criteria used-by the licensee. The Braidwood test report was submitted to the NRC by the Commonwealth Edison Company in 1985 to justify reduced separation of cables. That request was approved by the NRC in a Safety Evaluation Report issued on February 15, 1986. The Safety r Evaluation accepted 6-inch horizontal and vertical separation between cables. Also accepted were zero distance separation between cables in free air and those enclosed in conduit.

The NRC confirmed that the Braidwood tests performed by Wyle Laboratory and accepted by the NRC used similar or more limiting geometries than the acceptance criteria used by _-

F FitzPatrick. The licensee's safety evaluation stated that the Braidwood test data was one of -

!. the sources used to conduct their evaluation.

l Radiographic Review L NRC Inspection 50-333/92-21, conducted at Fitzpatrick on December 2, 3, and 4,1992, l reviewed radiographs accepted by NYPA and filed in their archival storage vault.

L Radiographs representing twenty-six welds were reviewed covering a period from July 11, _

l 1991, to October 11, 1992. There were three nonsafety welds (2 welder coupons and 1-nonsafety system) contained in the sample of twenty-six welds. Eight deviations from AS'ME ,

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[ requirements were identined in the remaining twenty-three welds. Five of the deviations l were contained in six welds while three deviations were of program requirements.

The licensee responded to these findings by implementing a Ove phase program that covered three basic areas. The three areas were (1) the specine infractions identified by the inspection, (2) the quality of radiographs and welds they represented, and (3) the root cause for the radiography problems, r -

The licensee used at least two Ixvel lil personnel supported by additional NDE qualified personnel to perform a review of all the radiographs taken from 1983 to the present. One of the Level 111 individuals was from Nine Mile Point and the second was a corporate Ixvel Ill individual from NYPA. These individuals used a specially formulated reader sheet to capture the essential parameters of each film reviewed. This included such things as film densities at three locations, section markers, penetrameter sensitivity and separate weld evaluation. The radiographs representing two hundred and twenty-five safety-related welds were reviewed in this manner.

The NRC performed a followup inspection on December 22 and 23,1993. This inspection resulted in the following conclusions: The licensee's program identified an additional eleven welds that required re-radiography or alternative volumetric examination in order to reach code compliance. Three of the re-radiographs verined the requirement for repair of a weld.

This is in addition to the one weld requiring repair that was identified by the NRC. The temporal distribution of all welds and radiographs out of compliance were: five in 1992, five in 1991, three in 1990, two in 1988, two in 1987 and none in 1985 or earlier. In order to verify the diminishing problems, the NRC selected two welds, at random, out of twenty-two in 1984 and found no additional deviations. A pattern became evident in the review of radiographic noncompliances that corresponded to the involvement of two key individuals (a contractor Level Il radiographer and the NYPA site Level III) associated with the program <

during the period of 1987 to present. The deterioration of the quality of the radiographs and interpretation was evident over the period of 1987 to present. Because the NYPA site Level 111 was on extended medical leave for parts of 1991 and 1992, there was a rapid decline in the quality of the radiographic program. During the time when the site Level III was not in l

full attendance, resulting in little NYPA review of the program,10 out of 17 problems 1 occurred.

Considering the extensive review program that was undertaken and the amount of detail that was covered, it can be concluded that the licensee arrived at the root cause for the problems identified in the original inspection. In light of the extensive review program, the NRC is confident that radiographs, which deviated from the requirements, and defective welds, which may have been put into place during the period when the radiography program deteriorated, have been identiGed and corrected.

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