ML20034F591
| ML20034F591 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 02/23/1993 |
| From: | Durr J, Modes M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20034F583 | List: |
| References | |
| 50-333-92-21, NUDOCS 9303040033 | |
| Download: ML20034F591 (6) | |
See also: IR 05000333/1992021
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION 1
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DOCKET / REPORT NOS. 50-333f92-21
LICENSE NO.
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LICENSEE:
New York Power Authority
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10 Columbus Circle
New York, NY 10019
FACILITY NAME:
J. A. Fitzpatrick
INSPECTION AT:
Scriba, New York
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INSPECTION DATES:
December 2-4,1992 and December 23,1992
INSPECTOR:
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M. C. Modes, Chief,
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Mobile NDE 12boratory, EB, DRS
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APPROVED BY:
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Jacqi}#P.'Durr, Chief, LTgineering
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Branch, Division of Reactor Safety
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9303040033 930224
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ADOCK 05000333
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Inspection Summary and Conclusions: An announced inspection was ' conducted by the NRC
at J. A. Fitzpatrick during the period December 2, 3, 4, and 23,1992, (Report No.
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50-333/92-21). The purpose of the inspection was to review final pipe weld radiographs.
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During this inspection, the NRC identified discrepancies in the radiographic program. -These
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discrepancies were discussed with the management of J. A. Fitzpatrick. Seven of the
discrepancies have resulted in violations.
The NRC reviewed corrective actions, taken by J. A. Fitzpatrick, during a follow up
inspection on December 23,1992. These corrective actions addressed the concerns raised by
the NRC during the initial inspection. As a consequence the NRC found the current
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radiographic program to be adequate to support restart of the facility.
Areas Inspected: Twenty'seven sets of radiographs were selected for review during the
initial inspection of 12/2 to 12/4/92. During the follow up inspection of 12/23/92 an
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additional eight radiographic packages were reviewed.
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1.0
INTRODUCTION
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The Code of Federal Regulations,-10 CFR 50.55a, requires that radiographic inspection be
performed in conformance with national standards. In the case of J. A Fitzpatrick,
ANSI B31.1 applies for all but the core spray line "A" which was inspected in accordance
with ASME Section III,1977 Edition, through Summer of 1977. The procedural
implementation of this requirement, for radiography, is J. .A. Fitzpatrick procedure RT-NIC-
013, Revision 3, dated 3/16/89, which 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. During this inspection, a number of discrepancies were identified which were
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brought to the attention of the management at J. A. Fitzpatrick. A number of violations have .
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been issued as a consequence of this inspection.
In response to this inspection, the management of J. A. Fitzpatrick established a program of
review and evaluation in order to address the concerns expressed by the NRC. ' On
December 23,1992, a second visit was made to J. A. Fitzpatrick in order to determine the
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status of the completed corrective actions. It was preliminarily determined that the concerns
of the NRC had been addressed to support restart of the facility. Actions .were planned by
the management of J. A. Fitzpatrick that would address the long term solution of the
problems.
2.0
RADIOGRAPHIC INSPECTION REVIEW (57090)
On December 3,1992, a review of the radiographs Sled in the archival storage building at
J. A. Fitzpatrick revealed radiographs for welds ISO 92-168, Jtem 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 doration 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 fihn retained in the archival
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storage building and therefore no way of assuring that the radiographic record will
deteriorate during storage. The ASME Code,Section XI, IWA-6310, requires that
radiographs be protected against deterioration. The failure to provide against deterioration
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constitutes a violation of the requirements (VIO 333/92021-01).
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The licensee offered the inspector the use of their radiographic densitometer in reviewing the
film. It was the densitometer they used in the analysis of their film. The densitometer was
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uncaFbrated. The licensee supplied a film strip for checking the accuracy of the
densitorneter. The film strip had certification or verification.of the density readings it
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contained. There was no evidence of a traceability to the National Institute of Technology
and Standards, as would be appropriate for the calibration of an instrument important to the
quality control of radiographic film. 10 CFR 50, Appendix B, Criterion XVII, requires that
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measures thall be established to assure that tools, gages, instruments, and other measurmg
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and testing devices used in activities affecting quality are properly controlled, calibrated, and
adjusted at specified periods to maintain accuracy within necessary limits. The use of an
uncontrolled, uncalibrated radiographic densitometer for the purposes of determining
radiographic densities, an activity affecting quality, as required by ASME Section V,
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Article 2, Paragraph T-282.1 of the 1986 Edition is a violation (VIO 333/92021-02).
The radiography at J. A. Fitzpatrick should be in conformance with the requirements of
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ANSI B31.1,1986 Edition which calls upon ASME Section V, Article 2, for the technical
details pertaining to radiography. This commitment is made on the part of J.~ A. Fitzpatrick
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in their final safety analysis report (Paragraph 16.5.5.1.1). Paragraph T-282.2 (a), of
Section V, requires that the optical density through the penetrameter be within -15% and
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+30% of the optical density measured through the area of interest that the penetrameter .
represents. In this edition of the code, the density may go above +30% if the penetrameter
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sensitivity is maintained. A review of the radiographs filed in the archival storage building
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at J. A. Fitzpatrick revealed radiographs for weld 3"-SHP-902-6, FW 10, Exposures 0-1 to
3-0, where the area of interest was measured to be less than -15% of the optical density
through the penetrameter representing the area. This is a violation (VIO 333/92021-03).
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ASME Section V, Article 2, in Paragraph T-292, requires that 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.
Filed in the archival storage building at J. A. Fitzpatrick were radiographs for welds 42-4-
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WD-153-68B, FW 32, Exposure 3-0, WM-92-682, FW 2, Exposure 3-4, and 10 MOV 89A,
SWI, Exposure 2-3 that contained linear indications that had either not been recorded or
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rejected or had been improperly interpreted and accepted. It was discovered in the review
program undertaken by J. A. Fitzpatrick, in response to this discovery, that the archival
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radiographic records contained two welds that required repair. The failure to evaluate and
reject linear indications is a violation (VIO 333/92021-04).
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Under the conditions of a nuclear power system, radiography must cover 100% of the
volume of the weld. In addition some of the base matedal must be covered to assure that
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cracks originating in the heat-affected-zone of the weld are also detected.' The ASME Code,
Section XI, Paragraph T-270, requires complete coverage of.the weld being radiographed.
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This requires that all the fusion zone of the weld be covered by radiography. Radiographs for ~
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weld 24-10-91 were evaluated, accepted and stored in the archive building at
J.' A. Fitzpatrick, and did not represent 100% of the fusion area of the weld. This omission
is a violation (VIO 333/92021-05).
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ANSI B31.1.0 requires, in Paragraph 136.4.5, that radiography be performed in accordance
with ASME Section V, Article 2, which in turn requires, in Paragraph T282.1, that the
minimum density for each film in a composite view be not less than 1.3. For single film
viewing the film may not be below 2.0 density. Contrary to this requirement, there were
radiographs filed in the archival storage building at J. A. Fitzpatrick for welds 10 MOV 27B,
Exposures 0-1 to 2-3 and 10 MOV 89A, SW1, Exposures 0-1 to 4-0 that had densities below
1.3. These mdiogmphs, evaluated and accepted, did not comply with the minimum density
requirements. This is a violation (VIO 333/92021-06).
ASME Section V,1986 Edition, Article 2, Paragraph T-282.1,
v. ares the maximum
radiographic density of film to be 4.0 for either composite or single film viewing.
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 24-10-997. to be
in excess of 4.0 density. This is a violation (VIO 333/92021-07).
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The licensee responded to these findings by implementing a five phase program that covered
three basic areas. The three areas were (1) the specific infractions identified by the
inspection, (2) the quality of radiographs and welds they represented, and (3) the root cause
for the radiography problems.
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The licensee used two I2 vel III personnel, along with other qualified support personnel, to
perform a review of all the radiographs taken from 1983 to the present. One of the
Level III's was from Nine Mile Point and the second was a corporate level III from NYPA.
These individuals used a specially formulated reader sheet to capture the essential parameters
of each film reviewed. This included such items as film densities at three locations, section -
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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 follow up inspection on December 22 and 23,1993. This inspection
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resulted in the following conclusions: The licensee program identified an additional eleven
welds that required reradiography or alternative volumetric examination in order to reach
code compliance. Three of the reradiographs verified the requirement for repair of a weld.
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This is in addition to the weld requiring repair that was identified by the NRC. The
temporal distribution of all welds and radiographs out of compliance was: 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 the year 1984 and found no additional deviations. The deterioration of the quality of _the
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radiographs and interpretation was evident over the period of 1987 to present. Because the'
NYPA site Level III was absent 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 full L
attendance, resulting in little NYPA review of the program, ten out of seventeen problems
occurred.
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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
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. identified in the original inspection, in light of this effort, the NRC is confident that
radiographs that deviated from the requirements and defective welds that may have been put
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into place during the period when the radiography program detuiorated have been identified
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and corrected.
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3.0
MANAGEMENT MEETINGS
The following individuals were contacted during the course of this inspection and attended
the exit meeting conducted on December 4,1992.
J. A. Fit 7 patrick
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R. Bauctt
General Manager Operations
M. Colomb
General Manager SS
H. Salmon
Resident Manager
N. Chapman
Welding Engineer
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G. Tasick
QA Manager
R. Lawton
QS Supervisor
A. Zareman
ORG Manager
D. Lindsey
General Manager Maintenance
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T. Moskalyk
Civil Engineering Manager
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W. Berzius
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Nuclear R.cgulatory Commission
W. Cook
Senior Resident Inspector
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