ML20034F587
| ML20034F587 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 02/24/1993 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20034F583 | List: |
| References | |
| 50-333-92-21, NUDOCS 9303040031 | |
| Download: ML20034F587 (3) | |
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New York Power Authority Docket No. 50-333 J. A. Fitzpatrick Power Station License No. DPR-59 During an NRC inspection conducted on December 2-4 and 23,1992, violations of NRC i
requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1992), the violations are listed below:
A.
10 CFR 50.55a(g) inservice inspection requirements, states that boiling water reactors 4
must meet the requirements of the ASME Boiler and Pressure Vessel Code,Section XI.
i The ASME Boiler and Pressure Vessel Code,Section XI, Paragraph IWA-6310 provides that owners shall maintain the records specified in IWA-634-0 in a manner to provide protection from deterioration and damage. Paragraph IWA-6330 designates nondestructive examination records, including radiographs, as inservice inspection records.
Contrary to the above, on December 3,1992, a review of the radiographs filed in the archival storage building at J. A. Fitzpatrick revealed radiographs for welds ISO 92-168, Item 3"-SHP-902-6, FW-10, exposures 0-1 to 3-0, taken April 24,1992, and Welder Coupons FW-5 and FW-6, exposures 0-1 to 3-0, taken March 6,1992, that had areas of undeveloped and\\or unfixed emulsion of a dark brown color. This indicates the presence of retained developing chemistry that could prevent the film from lasting for the duration required under the above requirements. Further the quality assurance program at J. A. Fitzpatrick does not have a procedure to determine the archival quality of radiographic film retained in the archival storage buildiug and therefore no way of assuring that the radiographic record will last for the duration required above.
This is a Severity Level IV Violation, Supplement I.
l B.
10 CFR 50, Appendix B, Criterion XVII, requires that measures shall be established to assure that tools, gages, instruments, and other measuring and testing devices used in activities affecting quality are properly controlled, calibrated, and adjusted at -
specified periods to maintain accuracy within necessary limits.
Contrary to the above J. A. Fitzpatrick utilized an uncontrolled, uncalibrated radiographic densitometer for the purposes of determining radiographic densities, an activity affecting quality, as required by ASME Section V, Article 2, 1
Paragraph T-282.1 of the 1986 Edition.
This is a Severity Level IV violation, Supplement I.
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i C.
10 CFR 50, Appendix B, Criterion IX, requires that special processes, including nondestructive examinations be performed in accordance with applicable codes, standards and specifications.
Fitzpatrick procedure for radiography, RT-NIC-013, Revision 3, dated 3/16/89, requires conformance with the requirements _ of the 1986 Edition of ANSI B31.1.0 and ASME Section V,1986 Edition with 1986 Addenda, as applicable. ANSI B31.1.0 l
requires, in Paragraph 136.4.5, that radiography be performed in accordance with ASME Section V, Article 2.
j (1)
ASME Section V,1986 Edition, Article 2, Paragraph T-282.2 (a), requires i
that the optical density through the penetrameter be within -15% and +30% of the optical density measured through the area ofinterest that the penetrameter represents.
Contrary to this requirement, on December 3,1992, a review of the radiographs filed in the archival storage building at J. A. Fitzpatrick revealed radiographs for weld 3"-SHP-902-6, FW 10, Exposures 0-1 to 3-0, where the area ofinterest was measured to be less than -15% of the optical density through the penetrameter representing the area.
i (2)
ASME Section V,1986 Edition, Article 2, Paragraph T-292, requires that the radiographs shall be examined and interpreted by the licensee as complying with the referencing Code Section. The licensee shall record the interpretation of each radiograph and disposition of the material examined on a radiographic interpretation review form accompanying the radiographs.
Contrary to this requirement, on December 3,1992, a review of the radiographs filed in the archival storage building at J. A. Fitzpatrick_ revealed radiographs for welds 42-4-WD-153-68B, FW 32, Exposure 3-0, WM-92-682, FW 2, Exposure 3-4, and 10 89A, SW1, Exposure 2-3 that contained '
indications oflack-of-penetration that had either not been recorded and rejected or had been improperly interpreted and accepted.
(3)
The ASME Code,Section V, Article 2, T-270, requires complete coverage of the weld being radiographed.
Contrary to this requirement, on December 3,1992, a review of the i
radiographs filed in the archival storage building at J. A. Fitzpatrick revealed radiographs for weld 24-10-91, evaluated and accepted, that did not represent 100% of the fusion area of the weld.
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(4)
ASME Section V,1986 Edition, Anicle 2, Paragraph T-282.1, requires the-7 minimum density for each film in a composite view be not less than 13. For single film viewing the film may not be below 2.0 density.
Contrary to this requirement, on December 3,1992, a review of the radiographs filed in the archival storage building at J. A. Fitzpatrick revealed radiographs for welds 10 MOV 27B, Exposures 0-1 to 2-3 and 10 MOV 89A, SW1, Exposures 0-1 to 4-0 that had radiographic densities below 1.3. These radiographs, evaluated and accepted, did not comply with the minimum density requirements.
(5)
ASME Section V,1986 Edition, Article 2, Paragraph T-282.1, requires the-l maximum radiographic density of film to be 4.0 for either composite or single film view'mg.
Contrary to this requirement, on December 3,1992, a review of the
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radiographs filed in the archival storage building at J. A. Fitzpatrick revealed radiographs for weld 24-10-997 to be in excess of 4.0 density.
Each of these constitute a Severity Level IV Violation, Supplement I.
Pursuant to the provisions of 10 CFR 2.201, New York Power Authority is hereby required to submit a written statement or explanation to the Regional Administrator, Region I, with a l
copy to the U.S. Nu:Icar Regulatory Commission, A*ITN: Document Control Desk, Washington, D.C. 20555, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or, if 3
contested, the basis for disputing the violation, (2) the corrective steps that have been taken -
and the results achieved, (3) the corrective steps that will be taken to avoid further j
violations, and (4) the date when full compliance will be achieved. If an adequate reply is -
not received within the time specified in this Notice, an order may be issued to show cause why the license should not be modified, suspended, or revoked, or whey such other action as i
may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.
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