JPN-92-075, Forwards Description of Action Plan to Address Concerns Re Insp of Radiography Program

Forwards Description of Action Plan to Address Concerns Re Insp of Radiography Program

ML20126F729
Person / Time
Site:	FitzPatrick
Issue date:	12/23/1992
From:	Ralph Beedle POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
JPN-92-075, JPN-92-75, NUDOCS 9212310089
Download: ML20126F729 (6)

Text

'

mw .,

WMc Plaint. New Yor610601 M4 CM (M6

1. '> NewYorkPower n. m o....

& Authority ll=;cg;"

December 23,1992 JPN 92 075 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station P1 137 Washington. D.C. 20555

SUBJECT:

James A. FitzPatrick Nuclear Power Plant Docket No. 50 333 Badiqgtaohv Program

Dear Sir:

The Nuclear Regulatory Commission performed an inspection of the Radiography program at the James A. FitzPatrick Nuclear Power Plant on December 2 through 4,1992.

At the exit meeting, the NRC identified a number of concerns. The Authority immediately assembled a project team to ovaluate and address the concerns. An action plan, divided into five concurrent phasos, was developed and immodlately implomonted. The status of radiography issues was discussed with NRC Region I staff on December 21,1992. An updated description is provided in the Attachment to this lotter.

l The Authority conducted a review of radiographs performed since 1985 based in

the reasons listed below. To provide further assuranco that the problems noted did not procede 1985, OA Category I radiographs from 1983 and 1984 were also reviewed. The

, quality of the radiographs and wolds from this period confirmed that the problems did not procede 1985.

• The 100% review of all Category I welds from 1983 to the present resulted in a confirmation that the welds at the FitzPatrick Plant are structurally sound.

l

• The four wolds with rejectable indications woro allinstalled in 1988 or later. There were no rejectable indications in welds installed prior to 1988.

• All OA Category I wolds and associated radiographs reviewed for modifications done from 1983 through 1987 were acceptable. Overall, the radiographs

performed from 1983 to 1985 are a much better quality than thoso performed later.

l e A review of personnel performing radiography indicated that the same individuals performed radiography from 1988 to 1992. One of those individuals was involved i

in radiography in 1987. Prior to this, different individuals were involved.

310011 f R12310089 921223 l p ADOCK 05000333 I\

l PDR l . _ _

,o 'The ten year Inservice Inspection hydrostatic test of the reactor vessel was .

performed during the 1985 refunling outage. Welds installed prior to 1985 have gone through at least four cycles of operation with no indication of structural integrity problems, in summary, approximately 870 radiographs of 225 OA Category I welds performed from January 1,1983 to the present were reviewed. Approximately 830 radiographs for 207 welds were acceptable. Radiographs of 18 welds were considered unacceptable.

Radiographs for 12 of these 18 welds were unacceptable based on film density. In addition, radiographs for one valve were discolored. These 13 welds were reexamined by radiography and are acceptable. One set of radiographs had minimum wall thickness concerns which were resolved by thickness measurements. Four radiographs showed rejectable indications. Four welds required rework and/or repair. The indications did not af feet the structuralintegrity of the welds and are detailed in the Attachment to this letter.

Based upon thls review, the Authority determined that programatic weaknesses existed in the administration of the radiography program. However, these weaknesses did not result in the acceptance of welds which compromised the structuralintegrity of safety related systems. The Authority is developing corrective actions to strengthen its administrative controls for radiography.

If you have any questions, please contact Mr. J. A. Grayi Jr.

Very truly yours, k W  :

Ralph E. Beedle ._

k Executive Vice President Nuclear Generation cc: U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Mall Station P 137 Washington, D.C. 20555 Office of the Resident inspector U.S. Nuclear Regulatory Commission P.O. Box 136 Lycoming, NY 13093 Mr. Brian C. McCabe Project Directorate 111 Division of Reactor Projects - 1/Il U.S. Nuclear Regulatory Commission Mall Stop 14 B2 Washington, DC 20555

. = . ..

i

~.

, New York Power Authority James A. FitzPatrick Nuclear Power Plant ATTACHMENT 1 to JPN 92-075 The Nuclear Regulatory Commission performed an inspection of the FitzPatrick radiography program on December 2 through 4,1992. At the exit meeting, the NRC identified a number of concerns. The Authority immediately assembled a project team to evaluate and address the concerns. An action plan, divided into five concurrent phases, was developed and immediately implemented. A detailed description of the five project phases is provided below.

PHASEI Phase i encompassed the review of all QA Category I radiographs performed from January 1,1983 to the present. Approximately 870 radiographs for 225 welds were reviewed.

The initial review was performed by a contract Level 111 Certified inspector and the final review and disposition of the acceptability of the rr .'iograph and weld by a NYPA Level 111 Certified inspector. The results of the review were:

• Approximately 830 radiographs for 207 welds were acceptable.

• Radiographs of 18 welds were unacceptable:

• Radiographs of 12 of these welds were unacceptable based on film density.

The Authority performed new radiographs of all these welds and supplemental ultrasonic examination on two welds. All welds are acceptable.

• One set of radiographs was discolored. This weld was reexamined by radiography and supplemental ultrasonic examination was performed.

• One set of radiographs had minimum wall thickness concerns which were resolved by thickness measurements.

• Four radiographs showed rejectable indications. Two weids required rework and two required repair. The rework on two welds was completed and is described below:

Weld WPF-902-3A on 34NRV-111 A, the feedwater non-return valve, had an indication on the inner surface. The area was visually examined using a videoprobe which confirmed the lack of penetration in approximately one inch of the weld root. The valve was disassembled and the area lightly ground. The weld was reinspected by radiography and is acceptable. Thickness was verified to meet minimum wall requirsments.

Weld SHP-902-17 on 13MOV-16, the HPCI steam supply outboard containment isolation valve, had an indication on the outer surface.

__ _ _ - . _ _ _ - . - - - - - . - - - - - - - - - ~ - - - - - - - - --

The area of the indication was visually and PT examined, and a line of porosity approximately 3/8 inch long was found. The weld was ground to remove the indication and rewelded. The weld was reinspected by radiography and is acceptable.

The necessary repair on two welds is described below: -

Weld 02 3028 BWOO9 is a one inch butt weld on a reactor vessel instrumentation system condensing pot which has a lack of fusion indication. It was modified and replaced with a socket weld on December 22,1992.

- Weld WM92 682 FW2 on 10MOV 398, the RHR suppre"cl >n pool cooling outboard containment isolation valve, has an i% 'on. An ultrasonic examination was ' performed which confirmei , ..adercut in excess of the 1/32" code allowable. The weld was;epaired and reexamined by radiography on December 22,1992.

The Authority initially determined that radiographs performed prior to 1985 do not need to I be reviewed for the reasons listed below. To proved further assurance that the probiems I noted did not precede 1985, QA Category I radiographs from 1983 and 1984 were also  !

reviewed. The quality of the radiographs and welds from this period confirmed that the-problems did not precede 1985.

e The 100% review of all Category I welds from 1983 to the present resulted in a .

confirmation that the welds at the FitzPatrick Plant are structurally' sound. With the exception of the four welds described earlier, all welds meet applicable code requirements.

e The four welds with rejectable indications were all inotud in 1988 or later. One '

was installed in 1992, two in 1990 and one in 1988. 'here were no rejectable indications in welds installed prior to 1988.

. o All five QA Category I welds and associated radiographs rev_iewed for-modifications y installed in 1985 were acceptable. Because of the limited. number of welds

~

installed in 1985, the Authority expanded the review to include the QA Category I radiographs taken in -1983 and 1984 to increase the confidence level.' All 30 QA Category I welds installed during this time period were reviewed and found to be

- acceptable. Overall, the radiographs performed from 1983 to 1985 are a much j- better quality than those performed later. =

e A review of personnel performing radiography indicated that the same individuals performed radiography from.1988 to 1992. One of these individuals was involved E in radiography in 1987. Prior to this, dif ferent individuals were involved. lj l e The ton year Inservice inspectidn hydrostatic test of the reactor vessel was

- performed during the.1985 refueling outage. Welds installed prior to 1985 have ,

gone through at least four cycles of operation with no indication of structural

, integrity problems.

7

PHAShll Phase ll consists of addressing the NRC inspector's specific concerns.

1. Two representatives from Kodak visited the FitzPatrick site, one on December 14, 1992 and one on December 15,1992. The first representative indicated that the ANSI standard addressing allowable relative humidity has been reduced from 30-40% to 20-30% She also said that the storage of diazos with silver master film and the use of rubber bands and plastic folders for storing radiographic film was not recommended. These concerns are being evaluated by NYPA and the appropriate action will be taken. The second representative said that the radiographic film was acceptable with no apparent deterioration and the archive facility was adequate.

He indicated that unfixed developer in the amounts found would not have any detrimental effect on the radiograph. However, the Authority will trim radiographs where necessary and newly developed film is being tested with a Kodak Hypo

Estimator kit. Kodak is expected to provido the Authority with a report of their review by December 31,1992.

2. Calibrated densitometers have been used for all radiograph reading since December 5,1992. A usage log to monitor linearity is being maintained.

3. The two potentially rejectable indications were dispositioned as follows:

Weld 42-4"-WD-153-68B W32 is a OA Category 11/111 weld on the non-safety related demineralized water system. The Authority initially planned to perform a visualinspection based on the close proximity of the weld to a bolted flange. We anticipated that the line could be easily drained and the flange opened for inspection. A further review indicated that a temporary operating procedure must be used and a temporary modification installed to gain access. Based on the difficulty in gaining access and that the line contains domineralized water at 90 psi with no safety related equipment in the vicinity, the Authority will not inspect the internal surface of the weld at this time. NYPA will evaluate if an inspection should be performed during a i future outage.

Weld WM-92-682 FW2 (10MOV-39B) was discussed earlier in this letter.

4. Weld 10MOV 27A-24-10-991 on the RHR LPCI injection outboard containment isolation valve was reexamined by radiography. Full coverage of the area of interest was achieved and the weld is acceptable.

5. Welds 24-10-997 and 24-10-998 on 10MOV 278 were reexamined by radiography and are acceptable.

6. Weld 10MOV-89A SW1 on the RHR heat exchanger service water outlet valve was reexamined by radiography and is acceptable with the exception of the lower five to six inches of the inner surface. This section contained water and possible pitting.

An ultrasonic examination of this area was performed and is acceptable. The ultrasonic examination also identified the pitting noted on the radiograph. The weld is acceptable based on the combined results of the two volumetric examinations.

l l

i. )

.7 . ' Welds W23-152-7A W1 and W2 on the Core Spray minimum flow valve,14MOV-SA received supplementary ultrasonic examinations. An Adverse Quality Condition Report was initiated to evaluate pitting detected during this examination. This indication is being evaluated and appropriate actions will be taken.

8. Wold 3' SHP-902 6 FW10 on 29MOV-77 was reexamined by radiography and is acceptable.

PHASE Ill Quality Assurance Procedure 9.3 " Administrative Controls for Non Destructive Examination Processes" has been drafted and is being reviewed. Elements of the procedure concerning independent Authority review of the radiography process, densitometer calibration and log keeping, and archiving of film are being implemented. The procedure will be fully implemented by December 31,1992.

Review of all Category I film reader sheets from 1983 through 1992 revealed a number of deficiencies. The acceptance criteria (code and revision) was not recorded on all reader sheets, not all sheets were signed, there were instances where the numbers on the filtn disagreed with the numbers on the reader sheet, there were instances where the film interpretation was done by the individual shooting the film, the geometric unsharpness (UG) calculation was not always recorded and the wrong penetrometer was noted. There was very little recorded Authority oversight of radiography and there were very few remarks to document recordable indications or analysis of indications. As the film was reread, a supplemental reader sheet was completed by a contractor Level til which more clearly describes the film and the interpretation. All 1983 through 1992 Category I radiographs and reader sheets were reviewed and approved by an Authority LevelIll, identified issues have been resolved with the exception of the two welds on 14MOV 5A described in Phase 11 item 7 above.

The FSAR indicates that the code of record for radiography examinations is ASME B31.1 -

1967 with the 1969 Addenda A. The Authority is preparing a safety evaluation in accordance with 10 CFR 50.59 to update the code of record to ASME Section XI- 1980, with Winter 1981 Addenda to be consistent with the code used for the FitzPatrick inservice Inspection program. The FSAR will be updated to reflect this change.

PHASE IV A root cause analysis, based on the INPO Human Performance Evaluation Process, is being performed. The report is scheduled to be completed by December 31,1992.

PHASE V The Director of ISI/NDE for Nuclear Energy Services remained at the FitzPatrick plant until the Authority and NRC inspector's reviews were completed on December 22,1992. He assisted the Project Team in evaluating the issues and in developing corrective action.