ML20044E325
| ML20044E325 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 05/10/1993 |
| From: | Eselgroth P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20044E321 | List: |
| References | |
| 50-333-93-06, 50-333-93-6, NUDOCS 9305240192 | |
| Download: ML20044E325 (26) | |
See also: IR 05000333/1993006
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U.S. NUCLEAR REGULATORY COMMISSION
Region I
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Report No.:
93-06
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Docket No.:
50-333
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License No.:
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Licensee:
New York Power Authority
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P.O. Box 41
Lycoming, New York 13093
Facility:
James A. FitzPatrick Nuclear Power Plant
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Iocation:
Scriba, New York
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Dates:
March 7,1993 through April 17, 1993
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Inspectors:
W. Cook, Senior Resident Inspector
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J. Tappert, Resident Inspector
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J. Caruso, Reactor Engineer
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M. Modes, Chief, Mobile NDE I4
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Approved by:
Peter W. EselgrothfChief
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Reactor Projects Section IB, DRP
INSPECTION SUMMARY: Routine NRC resident inspection of plant operations,
radiological controls, maintenance, surveillance, engineering and technical support, and
safety assessment / quality verification.
RESULTS: See Executive Summary
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9305240192 930514
ADOCK 05000333
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TABLE OF CONTENTS
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Puma No.
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1.0
SUMMARY OF FACILITY ACTIVITIES . . . . . . . . . . . . . . . . . . . . . . . . 1
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1.1
NYPA Activities . . . . . . . . . . . . . . . ; . . . . . . . . . . . . . . . . . . . . 1
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1.2
NRC Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
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2.0
PLANT OPERATIONS (IP 71707,71710,93702)
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2.1
Routine Plant Operations Review . . . . . . . . . . . . . . . . . . . . . . . . . . 1
2.2
U nit Startup . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
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2.3
Plant Transient Review . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
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2.4
Winter Storm Preparations and Response . . . . . . . . . . . . . . . . . . . . . 3
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3.0
RADIOLOGICAL CONTROLS (IP 71707) . . . . . . . . . . . . . . . . . . . . . . . . 3
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4.0
MAINTENANCE (IP 62703)
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4.1
EDG Maintenance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
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4.2
CRD Pump Maintenance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
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4.3
Review of RCIC Turbine 13TU-2 Oil Imel Critique
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4.4
Information Notice 92-54 Followup . . . . . . . . . . . . . . . . . . . . . . . . 5
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5.0
SURVEILLANCE (IP 61726) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
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5.1
Reactor Protection System (RPS) Surveillance Testing . . . . . . . . . . . . . 6
5.2
Inservice Testing of ESW . . . . . . . .
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5.3
Review of I&C and Operations Department Surveillance Testing
In terface . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
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6.0
ENGINEERING AND TECHNICAL SUPPORT (93702) . . . . . . . . . . . . . . . 8
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6.1
Recirculation Riser Decontamination Connections . . . . . . . . . . . . . . . . 8
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6.2
Review of RHR Pump Minimum Flow Line Check Valve Testing . . . . . . 9
6.3
Followup of Previous Fire Protection Inspection Findings . . . . . . . . . .
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6.4
Followup of Fire Protection Items Completed After Plant Startup . . . . .
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6.5
Followup of I.ong Term (LT) Fire Protection Actions . . . . . . . . . . . .
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7.0
SAFETY ASSESSMENT / QUALITY VERIFICATION (71707,93702) . . . . . .
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7.1
Review of Licensee Event Reports (LERs) and Special Reports . . . . . .
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7.2
Radiography Review Followup . . . . . . . . . . . . . . . . . . . . . . . . . .
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8.0
M ANAGEMENT MEETINGS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23
NOTE: 'Ibe NRC inspection manual procedure or temporary instruction that was used
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as inspection guidance is listed for each applicable report section.
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Executive Summary
James A. FitzPatrick Nuclear Power Plant
NRC Region I Inspection Report No. 50-333/93-06
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03/07/93 - 04/17/93
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Plant Operations: Plant operation was good throughout the inspection period. Detection of
the decontamination connection leak during the drywell inspection and site management's
decision to shutdown to resolve this problem were appropriate. Precautionary actions taken
by the site staff during the severe winter storm in early March were good. Observations of
operator performance during the unit startup on March 20 were positive overall. The nuclear
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control operator's actions on April 15 to avert a reactor scram were particularly noteworthy.
Maintenance: The inspectors reviewed maintenance performed on the B emergency diesel
generator and the B control rod drive pump. Appropriate work control and proper
radiological control practices were observed. NYPA's response to Information Notice 92-54,
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involving reactor vessel level instrumentation inaccuracies, was reviewed and found to be
appropriate. Review of a RCIC turbine lube oil problem critique identified a thorough
assessment of the problem and good corrective action.
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Surveillance: Inspector review of the incomplete testing of the APRM flow-biased scram
function concluded that the resolution to the testing deficiency was proper and that additional
corrective actions taken to scope the problem were satisfactory. A review was conducted of
instrumentation and controls department interface with operators for surveillance testing and
identified appropriate controls and coordination of work activities.
Engineerine and Technical Support: Inspector followup of previously identified fire
protection program findings concluded that most of the issues were properly resolved.
Inspector followup of the decontamination connection threaded cap leak identified that post-
modification testing prescribed by the installation procedure for these new connections was
not properly conducted. This is a violation of NRC requirements (VIO 93-0641). Inspector
review of the resolution of residual heat removal pump minimum flow line check valve
inservice testing was not initially rigorous, but was appropriately resolved.
Safety Assessment /Ouality Verification: Review of Licensee Event Report 93-06
concerning inoperability of fire pumps identified an inaccurate chronology of events.
Submission of inaccurate or incomplete information to the NRC is a violation of 10 CFR 50.9 (VIO 93-06-02). This LER error was of minor safety consequence, but is a recurring
problem. Inspector followup of a previously identified radiography concerns concluded
actions taken by NYPA to resolve these issues were good.
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DETAILS
1.0
SUMMARY OF FACILITY ACTIVITIES
1.1
NYPA Activities
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At the beginning of this inspection period, a unit restart was in progress following a planned
maintenance outage. On March 7 a drywell inspection at 1000 psig identified a steam leak
on the J recirculation riser decontamination connection threaded end cap. NYPA aborted the
unit startup and shutdown early on March 8. Following a modification to all ten of the
decontamination connections, the unit was restaned on March 20 and operated at power
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through the end of the inspection period. A plant transient on April 15, which could have
resulted in a reactor scram, was averted by prompt operator action and is discussed in section
2.3 below.
1.2
NRC Activities
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Inspection activities during this report period included normal, backshift and weekend hours
by the resident staff. There were 27 hours3.125e-4 days <br />0.0075 hours <br />4.464286e-5 weeks <br />1.02735e-5 months <br /> of backshift (evening shift) and 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> of deep
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backshift (weekend, holiday and midnight shift) inspections during this period.
A region-based inspector conducted an inspection of FitzPatrick's fire protection program
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during the week of March 8,1993 (see section 6.3).
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Region-based inspectors conducted an inspection of FitzPatrick's emergency operating
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procedures during the week of March 18,1993 (reference report 93-07).
A region-based inspector conducted an inspection of FitzPatrick's radiography program
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during the week of April 5,1993 (see section 7.2).
Region-based inspectors conducted an inspection of FitzPatrick's radiation protection and
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health physics programs during the week of April 12,1993 (reference report 93-09).
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2.0
PLANT OPERATIONS (IP 71707,71710,93702)
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2.1
Routine Plant Ooerations Review
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During the inspection period the inspectors observed control room activities including
operator shift turnovers, shift crew briefings, panel manipulations and alarm response, and
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routine safety system and auxiliary system operations conducted in accordance with approved
operating procedures and administrative guidelines. The inspectors made independent
verification of safety system operability by review of operator logs, system markups, control
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panel walkdowns and component status verifications in the field. Discussions were held with
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operators and technicians in the field to assess their familiarity with current system status and
personnel response to events during the inspection period. In addition, during plant tours,
inspectors reviewed routine radiological control pmetices. The activities inspected were
acceptable.
2.1.1 Operational Safety Verification
The inspector conducted partial control room and in-plant walkdowns of the following
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systems:
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A and C emergency diesel generators
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A and B standby liquid control
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A and B emergency service water
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High pressure coolant injection
Minor housekeeping discrepancies were noted by the inspectors and appropriately addressed
by the licensee, but no problems impacting system operability were noted.
2.2
Unit Startuo
Portions of the reactor startup were observed on March 20,1993. The mode switch was
taken to STARTUP at 8:57 a.m. and rod withdrawal commenced at 9:14 a.m. The startup
was conducted in a slow, methodical, and professional manner. The operators fully
complied with Operating Procedure (OP)-65, Stanup and Shutdown Procedure, and senior
operations management closely monitored the startup. The inspector noted that formal
guidance in the use of the estimated critical position (ECP) and required operator actions if
criticality is not achieved within the expected band have not been proceduralized.
Discushns with station management identified that this will be accomplished in the near
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future. Communications between the reactor analyst and reactor operator were good and
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there was no question about who was controlling reactivity. Criticality was achieved at
12:14 p.m. within the ECP acceptance band. The overall startup evolution was conducted
well.
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2.3
Plant Transient Review
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At 9:38 p.m. on April 15, 1993, while operating at 100% reactor power, a reactor vessel
level transmitter (MLT-52A) failed high. The feedwater control system was selected to
single element control (reactor vessel level only) and the A level column was providing the
controller input. The feedwater control system sensed a high reactor vessel level and
responded by automatically running back reactor feedwater pumps. An alert nuclear control
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operator (NCO) observed both the low reactor vessel level alarm and the pegged high
channel A level instrument (06LI-94A) and recognized the instrument failure situation. The
NCO promptly took manual control of both reactor feedwater pumps to restore level to the
normal control band and selected the B level column for feedwater control system input.
The inspector noted that the entire level transient was over in a few minutes, and if not for
the prompt action of the NCO, the unit most likely would have scrammed. Subsequent
discussions with NYPA site managers identified that licensed operators are subjected to
similar transients during simulator training (in comoination with additional failures) and are
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not expected to be able to recover level in time to avert a reactor scram. The operator's
response to the April 15 event was particularly noteworthy.
2.4
Winter Storrn Precarations and Resoonse
During the weekend of March 13,14, and 15,1993, a severe winter storm hit the East Coast
of the United States. Strong winds and significant accumulations of snow were experienced
in the local area. During this time period the unit was already shutdown and in anticipation
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of severe weather conditions. Plant management stopped all outage work through the
weekend to minimize staffing requirements. In preparation for this storm, the FitzPatrick
staff brought in additional food stores and bedding for personnel unable to return home from
the plant. Additional operators, security guards and firewatches were called in by plant
management to ensure adequate manning of the facility and to reduce the risk of plant staff
travelling to and from the plant. The inspectors reviewed the storm preparatory measures
with plant management and monitored plant activities and storm impact via telephone through
the weekend. No difficulties were encountered.
3.0
RADIOLOGICAL CONTROLS (IP 71707)
The inspector observed routine radiological work practices during observation of various
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maintenance activities and in routine tours of the plant. In general, radiological workers
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appeared to be well-trained and were observed to be using appropriate radiological work
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practices (i.e., bagged tools and other items, as required, maintained work areas clean,
removed protective clothing properly, dosimetry worn properly, and all radiological postings
obeyed). The health physics technicians maintained close surveillance over the work
activities in their assigned areas. The radiological work areas, in general, were well-
maintained (i.e., clean with appropriate radiological postings). The inspector concluded that
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the workers and health physics technicians were working well together to ensure safe and
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appropriate radiological work practices.
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4.0
MAINTENANCE (IP 62703)
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Observation of Maintenance Activities
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The inspector observed and reviewed selected portions of preventive and corrective
maintenance to verify compliance with codes, standards and Technical Specifications, proper
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use of administrative and maintenance procedures, proper QA/QC involvement, and
appropriate equipment alignment and retest. The following activities were observed:
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4.1
EDG Maintenance
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The inspector observed troubleshooting of the B emergency diesel generator (EDG) stator
temperature resistance thermal detector (RTD). Work Request (WR) 82544 was written in
February 1992, following the installation of the Emergency and Plant Information Computer
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(EPIC) point detector to resolve questions about differences in lead resistances of this three-
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wire detector. This WR was being worked at this time as part of a system window in the
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rolling 13-week schedule. The technicians were extremely knowledgeable and worked in
accordance with their general work instructions and ODSO-12, Generic Troubleshooting and
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Maintenance Procedure. No deficiencies were noted.
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4.2
CRD Pumo Maintenance
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Portions of the B control rod drive pump replacement were observed on April 14,15, and
16, 1993. The pump was being replaced during another window in the 13-week rolling
schedule in response to degrading performance observed during surveillance testing. Repair
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work was complicated by discharge check valve leakage. The inspector noted that the
internals of this valve were removed for replacement and that the leakage past the upstream
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isolation valve was appropriately diverted while repair work on the pump progrmed. The
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mechanics appeared knowledgeable of the work and the maintenance chief was on hand to
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provide assistance and guidance. The radiation technician for the job was also at the work
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site and was closely involved with the maintenance. Radiological control practiccs were
observed to be satisfactory.
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4.3
Review of RCIC Turbine 13TU-2 Oil 12 vel Critiaue
During unit startup from the 1992 refuel outage a number of minor events occurred which
were critiqued by NYPA to identify equipment and/or personnel performance concerns and
to implement appropriate corrective actions. One such event involved the observation of
abnc,rmal lubricating oil level in the reactor core isolation cooling (RCIC) turbine per ST-
24M. The critique of this event was documented by memorar.dum JMD-93-045, dated
January 18, 1993.
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The inspector reviewed the critique and determined it to have been technically accurate,
appropriately self-critical, and the recommended corrective actions to be satisfactory.
Formal documentation of critiques, such as this, has been implemented by the FitzPatrick
staff for over a year. These critiques, in general, are reasonably thorough in identifying root
and contributing causes and in providing reasonable actions to prevent recurrence.
4.4
Information Notice 92-54 Followuo
NRC Information Notice No. 92-54 " level Instrumentation Inaccuracies Caused by Rapid
Depressurization" was issued on July 24,1992 in response to inaccuracies detected in
pressurizer 1:vels at Millstone Unit 3. The Boiling Water Reactor Owners Group (BWROG)
analysis indicated that the error experienced at a BWR would not exceed four inches if the
reference leg configuration is installed in accordance with vcador recommendations.
Further analy6 documented in Generic letter 92-04 " Resolution of the Issues Related to
Reactor Ves';ci Wuter Level Instrumentation in BWRs Pursuant to 10 CFR 50.54(F)"
indicated tLat sign ficant errors in level indication can occur as a result of degassing the
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instrument reference leg if non-condensable gas is dissolved in the reference leg and the
reactor abruptly depressurizes below 450 psig. The amount of non-condensable gases
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dissolved in each reference leg (there are more than one per reactor) depends on system
leakage and geometry. Because of this a common mode and/or common magnitude level
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indication error is unlikely. Therefore, operators would likely see a mismatch in indicated
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According to NYPA site representatives, the unit has not had any indication of a level
mismatch, nor had the plant experienced any level instrumentation inaccuracies during
normal plant depressurizations as portrayed in NRC Information Notice 93-27. The site staff
did not have evidence or experience that would lead them to believe they had non-
condensable gas problems in the reactor vessel level instrumentation system. However,
information gathered while attending a BWROG meeting led NYPA to initiate a modification
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to provide thermal monitoring of the reference leg condensing chambers. This action was
independently taken by NYPA and was beyond the current BWROG recommendations.
Monitoring the differential temperature between the steam (top) and water (bottom) portions
of the condensing chambers provides an indication of a potential non-condensable gas
problem.
The FitzPatrick modification consists of two phases. Phase one of the FitzPatrick
modification was completed prior to unit restart from the refuel outage and consisted of
mounting two thermocouples on five condensing pots and terminating the thermocouple leads
at a drywell penetration. In order to conserve wire, time and manpower in phase one of the
modification, NYPA wired each set of thermocouples in series. Therefore, each condensing
pot had two thermocouples mounted with a total of three electrical leads (in series).
However, the site staff discovered prior to the January 1993 restart, that the thermocouples
would not report a true differential temperature when wired in series. Consequently prior to
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restart, an additional wire was run between each condensing pot and the drywell penetration
so the thermocouples could be wired separately. Therefore, NYPA now had the capability to
monitor the absolute temperature of the steam and the water and could now calculate a true
differential temperature. The thermocouples were never disconnected; they were only re-
terminated at the drywell penetration. Phase two of the modification consists of connecting
the thermocouple leads to the plant computer to process and gather their temperature outputs
for condensing pot performance evaluation. Phase two was partially complete prior to restart
(two of five condensing pots monitored) in that some thermoenuple absolute temperature data
was collected during the unit startup and power ascension.
Insoector Conclusions
The inspector determined from interviews that the absolute temperature data taken to date
was still being evaluated by the FitzPatrick staff. However, preliminary evaluation of the
temperature data was that it is not indicative of the non-condensable gas problem seen at
other nuclear facilities. Additional data must be gathered and evaluated before a definitive
interpretation of the data can be made and used to determine the presence of a non-
condensable gas problem. Consequently, the NYPA site staff maintains that the reactor
vessel level indication systems are operable based upon satisfactory surveillance testing and
calibration results and good agreement between level channels as observed during steady state
and plant transients. The inspector had no issue with this operability determination.
Overall, from interviews with responsible site managers, engineers and instrumentation and
controls department staff, the inspector determined that NYPA was appropriately evaluating
the available condensing pot temperature data.
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SURVEILLAW 2 (IP 61726)
The inspector observed and reviewed portions of ongoing and completed surveillance tests to
assess performance in accordance with approved procedures and Limiting Conditions for
Operation, removal and restoration of equipment, and deficiency review and resolution. The
following observations were made:
5.1
Reactor Protection System (RPS) Surveillance Testing
During unit startup on March 22,1993, shortly after the mode switch was taken to RUN,
ST-5B, APRM Instrument Functional Test (RUN Mode), was performed. During the
performance of the surveillance, several of the average power range monitors (APRMs) were
found out of procedural tolerance, specifically the A, E, B, and F downscale rod block, the
C, D, and E upscale rod block, and the E upscale trip. The inspector noted that prior to
startup from the refueling outage, the acceptance ranges for these setpoints were all reduced
to conservatively account for instrument drift and inaccuracies. While the tighter bands
cause little difficulties for the I&C technicians who perform their surveillances with a digital
voltage meter (DVM), it did cause problems for the operations staff who use the analog
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meter on the face of the APRM cabinet. This was the apparent cause of the out of tolerance
readings, as the values were subsequently found within specification limits using the DVM.
Control room operators' immediste response to the out of specification readings was to trip
the A RPS char.nel and lower power into the iritermediate range to comply with Technical
Specifications. The operations staff subsequently modified their procedures so that the I&C
procedures using the DVM would provide the calibration checks and the operations
procedure would simply provide the functional checks (i.e., inserting half scrams). The
inspector learned that these procedural revisions were already being processed, but the effort
was accelerated due to the surveillance test failures.
During the procedural review process, it was discovered that the APRM flow biased upscale
thermal power trip function sas not verified to actually result in an APRM scram signal to
the RPS logic because the I&C procedures were conducted with the APRMs bypassed. For
all other scram input signals, the channels are calibrated with an I&C procedure while the
instrument is bypassed and then functionally tested during an operations surveillance test.
This was not the case for the flow-biased APRM scrams. No violation of TS occurred since
FitzPatrick TS Table 4.1-1 only requires that the flow bias signal be calibrated monthly.
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However, NYPA took the position that they did not adequately demonstrate operability of
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this function and will submit an LER, accordingly.
The inspector verified that the flow-biased trip function was incorporated into the I&C
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procedure, and the revised I&C and operations surveillances were PORC approved. The
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surveillances were then performed satisfactorily, and the startup continued. Portions ofISP-
20B, APRM Upscale and Downscale Instrument Calibration, were observed. The procedure
was well conducted with no deficiencies noted.
The inspector concluded that NYPA's review and resolution of this issue was thorough. The
LER will be reviewed in a future inspection report.
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5.2
Inservice Testine of ESW
Portions of ST-8Q, Testing of the Emergency Service Water System OST), were observed.
The test verifies the adequacy of emergency service water (ESW) flow to the various unit
coolers. The test was well conducted. The system engineer was closely involved with the
test and reviewed data at the work site. ST-8N, ESW Pump Inservice Test, was also
reviewed. No discrepancies with either test were noted.
5.3
Review of I&C and Operations Denartment Surveillance Testine Interface
The interfaces between the Instrumentation and Controls O&C) department and Operations
department during the conduct of surveillances was reviewed. The I&C surveillance test
procedures are uniform in their prerequisite requirements for shift supervisor's permission
prior to commencing the test. The I&C technician documents this permission by the shift
supervisor's initial on the data sheet. The inspector reviewed several completed surveillances
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to verify permission was properly documented. These actions were additionally validated by
the corresponding entries in the control room operator's log. Another I&C/ Operations staff
interface reviewed by the inspector was the manipulation of equipment controls and
annunciators on the control room panels. Operations Department Standing Order (ODSO)-2,
Operating Principles and Philosophy, provides guidance that allows non-licensed personnel to
manipulate certain panel controls with the knowledge and permission of the control room
operators. The standing order excludes reactor control manipulations and requires the
operators to be immediately notified of any unanticipated. alarm or system actuations. This
practice has been observed by the inspectors in the past. Overall, these actions werc
considered appropriate and acceptable administrative controls and guidance have been
demonstrated. In summary, the conduct of I&C technicians and their interface with the
opera: ions staff during the performance of surveillance testing was observed to be appropriate
and in accordance with prescribed standards and regulations.
6.0
ENGINEERING AND TECIINICAL SUPPORT (IP 93702)
6.1
Recirculation Riser Decontamination Connections
"roblem Identification and Resolution
On March 6,1993, the reactor was started following a one week maintenance outage. Later
that day during the reactor pressure vessel 1000 psig inspection, a leak vras discovered in the
threaded cap downstream of 02-2RWR-715, the isolation valve for me decontamination
connection on the J recirculation riser. The isolation valve and threaded cap assembly was
typical of ten decontamination connections and was installed during the 1992 refueling
outage. After discovery of the leak, the plant startup evolution was discontinued and the
plant was shutdown to perform repairs.
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Modification M1-91-004 installed branch lines with isolation valves and valve caps on the
recirculation jet pump risers in order to reduce personnel radiation exposure by reducing the
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time required to connect and remove decontamination equipment. After the unit was
shutdown and closer inspections of all decontamination connections were made, questions
were raised concerning the acceptability of using a threaded cap as a primary pressure
boundary. The justification for this design was not documented in the original modification
package. However, after considerable effort, NYPA was able to determine that the threaded
cap design was allowable per ANSI B3.1.1-67, the construction code for FitzPatrick. While
the design was determined to be acceptable, further NYPA review also identified that only
two of the ten connections had adequate thread engagement of the end caps. The lack of
adequate thread engagement was attributed to a lack of specific instructions for cap
installation. After further review of the threaded cap design and difficulties encountered in
attempting to seal weld tne leaking cap on the J recirculatioa riser, NYPA decided to alter
the design by replacing the threaded caps with socket welded blank flanges. The flanges
were installed on all of the connections and no leakage was noted during the subsequent
startup.
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Inspector Followup
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Modification M1-91-004 required that all new welds that remain part of the reactor coolant
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pressure boundary be leak tested at 1000 psig during ST-39H, Reactor Pressure Vessel
System Leakage Test. However, the inspector determined that ST-390, Reactor Pressure
Vessel System Ieakage Test With Reactor Coolant Temperature Below 212*F, (which was
performed in lieu of ST-39H) did not open the decontamination isolation valves so that the
welds downstream of the valves were pressurized. The inspector concluded that the post-
modification testing requirement to pressure test these welds was not accurately translated
into the surveillance test and was not performed. The failure to pressure test these welds
was contrary to modification M1-91-004, Installation Procedure No.1, Section 10 and is a
violation of NRC requirements (VIO 93-06-01). NYPA subsequently determined that these
new connections are exempt from ASME Code Section XI leak testing since they are one-
inch diameter piping. Notwithstanding, the post-work testing specified in the modification
package was not performed as specified.
In summary, NYPA's response to the decontamination connection leakage was adequate, in
that, the modification design issue was thoroughly resolved prior to restarting the unit.
However, weaknesses were noted with several phases of the modification process including:
adequacy of design verification; deficiencies in the installation procedures; and failure to
follow post-modification testing requirements. The inspector is aware that a detailed NYPA
root cause evaluation and correction action plan was developed subsequent to the inspection
period. This information will be reviewed in a subsequent inspection period as part of the
violation followup.
6.2
Review of RHR Pumo Minimum Flow Line Check Valve Testing
On March 11, NYPA conducted surveillance test (ST)-2A, RHR Pump Flow Rate and
Inservice Test, on the B and D residual heat removal (RHR) pumps to verify the proper
functioning of the minimum flow line check valves (10 RHR 64B and 64D, respectively).
The results of this test were that the 64D check valve tested unsatisfactorily and the 64B
check valve was satisfactory. The inspector determined that to perform this inservice test, a
strap-on ultrasonic flow meter is attached to the piping downstream of the check valves and
the criteria for proper check valve operation is a measured flow of greater than 350 gpm.
Difficulty in obtaining consistent and repeatable results has been experienced by the NYPA
staff since first conducting this test in 1992. Because of the highly turbulent flow at the
point where flow is measured, frequently the ultrasonic flow measuring device loses the flow
signal before obtaining a satisfactory minimum flow measurement.
On March 12, ST-2A was reperformed and during this test the 64B check valve was tested
unsatisfactory and the 64D check valve was satisfactory. Because of the history of
inconsistent test results due to the limitations of the flow measuring device and RHR system
configuration, the NYPA technical services staff stated that in lieu of obtaining a satisfactory
reperformance of the inservice test on check valve 64B, that an evaluation describing the
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limitations of the flow measurement methodology be documented and that the last satisfactory
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64B check valve test results (March 11,1993) be used for an operability determination vice
the March 12 results. The inspectors questioned whether this approach was based upon
sufficient material history and performance information being presented for review and
considered that a less than rigorous engineering evaluation was made of the potential for
actual check valve inoperability.
Later on March 12, the 64B check valve inservice test was run using a different test
methodology which minimized the flow tmbulence during flow measurement on the
downstream piping. During this test the maximum flow achieved was 280 gpm. A work
request was initiated and when the valve bonnet was removed a 3-inch by 3/4-inch hexagonal
head carbon steel bolt was found lying on top of the check valve disc. The bolt evidently
inhibited full range of motion of the check valve disc, but not one hundred percent of the
times tested. No physical damage to the 64B check valve internals was noted. After
removal of the bolt, a satisfactory inservice test was performed. The inspector notes that an
investigation by the FitzPatrick staff was inconclusive as to how the 3-inch bolt was
introduced into the system.
After a detailed review and evaluation of the minimum flow line check valve testing
!
methodology and results achieved, to date, the technical services staff revised the inservice
testing requirements for these valv . The check valves will be exercised on a quarterly
basis during RHR pump testing, and once per operating cycle, at least one check valve will
be disassembled and inspected. The inspector reviewed the revision to the inservice testing
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program prepared for and approved by the Plant Operations Review Committee. The
revision was in accordance with 10 CFR 50.55a(g) and the guidance provided in Generic
I2tter 89-04, Guidance on Developing Acceptable Inservice Testing Programs.
Conclusion
The inspector concluded that the technical services staff appropriately resolved the inability
to satisfactorily perform in-line flow testing of the RHR pump minimum flow line check
valves (10 RHR 64A, B, C, & D) by providing a proper technical justification for an
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alternative testing methodology. However, the March 12 evaluation to justify and accept
unsatisfactory tests results was not rigorous and lacked a conservative approach to resolving
the technical issue.
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6.3
Followup of Previous Fire Protection Inspection Findings
Introduction
All of the outstanding post-startup fire protection / Appendix R action items had been targeted
for completion by March 31,1993 and some by December 31,1992 as stated in NYPA letter
JPN-92-023, dated May 27,1992. Work on most of these items had not been started or
rescheduled. In some cases, funding has not been allocated. NYPA is preparing a new
schedule for completion of all outstanding fire protection / Appendix R items.
6.3.1 Violation (EEI 333/92-80-15A. ISB.15C. ISD.15E.15F)
This violation dealt with NYPA's failure to implement an effective Fire Protection Program
as required by Amendment No. 47 to the FitzPatrick Facility Operating License Condition,
2.C.(3). All but one part of this multi-part violation was closed (i.e. EEI 333/92-80-15A,
ISB,15C,15D,15E) based primarily on earlier inspection efforts that were conducted prior
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to the NRC's acceptance of NYPA's response to the Notice of Violation (NOV). These
items had been reviewed in earlier inspections to verify adequate corrective actions prior to
plant startup. In addition, some confirmatory verifications of NYPA's corrective actions
were conducted during the current inspection. The disposition of each part is discussed
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below. The inspector did not review item EEI 333/92-80-15F as this part of the violation
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deals with a long term commitment to upgrade fire fighting pre-plans and was not complete
at the time of the inspection.
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6.3.1.1 (Closed) Violation
El 333/92-80-15A)
This part of the violation dealt with the failure to implem'ent a program of inspections to
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control combustibles in safety related areas, assure availability and acceptability of fire
protection equipment, and assure prompt and effective corrective actions for conditions
adverse to fire protection as required by Amendment No. 47 to the FitzPatrick Facility
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Operating License.
In JPN-92-063, NYPA's response to the NOV, section III.A.1, NYPA stated fire protection
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equipment is in the process of being upgraded and the fire brigade equipment is being
adequately maintained. The fire brigade drill evaluation process now includes provisions to
note deficient equipment and initiate remedial actions.
The inspector toured the plant and reviewed completed Fire Inspector logs to verify daily
inspections were being conducted to minimize the amount of combustibles in safety related
areas, assure availability and acceptability of fire protection equipment, and assure prompt
and effective corrective actions for conditions adverse to fire protection. The inspector also
reviewed the results of the annual fire brigade tumout gear inspection conducted for 1993 as
required by procedure FPP-2.24. The inspector noted several deficient conditions that had
been identified and already corrected. In addition, the inspector noted that the Fire
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Protection Supervisor had identified a problem with cracked fire hoses and had taken actions
to have the hoses replaced. Finally, during plant tours the inspector verified that the fmdings
identificd in section 2.5.5 of inspection report 50-333/92-80 (related to fire equipment
deficiencies) were resolved with the exception of two items: (1) the sprinkler protection
provided in the old maintenance shop area, elevation 272; and (2) the thermal detectors
located on the vertical wall surfaces that activate the stairwell water cunains in the reactor
building. These items will be addressed by NYPA as part of their NFPA code compliance
walkdown and are a separate open item being tracked as an NRC Inspection Followup Item.
The corrective actions taken by NYPA to resolve this violation also were reviewed during
previous inspections (repon 50-333/92-15, section 6.2.1 and report 50-333/92-14, section
3.2). Based on these reviews, the inspector concluded that the actions taken by NYPA are
adequate to resolve this violation. Violation 92-80-15A is closed.
6.3.1.2 (Closed) Violation EEI 333/92-80-15B)
This pan of the violation dealt with failure to adequately implement the license condition
requirements for the control of combustibles and identified numerous examples of improper
storage of transient combustibles throughout the plant. In section III.A.3, of the response to
the NOV, NYPA stated that all plant work was stopped for a clean-up of excess
combustibles. Formal standards were introduced through plant directives and procedure
improvements. Additional trained fire inspectors were assigned at a level commensurate with
plant work.
The inspector verified satisfactory implementation of the corrective actions identified in the
NOV response. The inspector toured the plant to verify adequate control of combustibles
and compliance with Work Activity Control Procedure (WACP) 10.1.10, " Control of
Combustibles and Flammable Materials." A selected sample of six active Combustible
Control Permits were reviewed in the plant. The cleanliness of the plant and the
implementation of the Combustible Controls Program were observed to be satisfactory and
improved over previous inspections when this same item was reviewed. The programmatic
controls established in procedure WACP 10.1.10 appear to provide adequate guidance for the
control of transient combustibles in the plant.
The combustible controls for the waste material storage area elevation 272 of the turbine
building track bay area were judged to be satisfactory at the time of the inspection.
However, the inspector determined that the controls established in WACP 10.1.10 for this
area could be improved. These additional controls would ensure responsibilities were clearly
established to address the unique conditions associated with this particular area. Site
management agreed to revise WACP 10.1.10 and 10.1.14 in an effort to improve the
combustible controls established for this area. This storage area is a transient ama for
hazardous combustible waste material leaving the plant. For this area, site management is
also considering options to reduce the quantity of combustibles stored and to assess alternate
storage areas outside the power block.
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The corrective actions taken by NYPA to resolve this violation also were reviewed during
previous inspections (repon 50-333/92-03, section 5.0; report 50-333/92-15, section 6.2.2;
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and repon 50-333/92-14, section 3.2.3 and 8). Based on these reviews, the inspector
concluded that the actions taken by NYPA were satisfactory to resolve this violation.
Violation 92-80-15B is closed.
6.3.1.3 (Closed) Violation GEI 333/92-80-15C)
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This pan of the violation indicated failure to adequately develop an adequate program for
ignition source control as required by Amendment No. 47 to the FitzPatrick Facility
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Operating License. In the response to the NOV, section III.A.4, NYPA stated all hot-work
was stopped until a new welding (Ignition Source Control) procedure was developed and
training was completed. This procedure includes a sign-off by the foreman, an inspection of
the work site and a review of the planned hot-work by fire protection personnel, required fire
watch signature on the permit, and a close-out inspection of the work area by fire protection
personnel.
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The corrective actions taken by NYPA to resolve this violation were reviewed during
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previous inspections (reports 50-333/92-15, section 6.2.3 and 50-333/92-14, section 8). The
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inspector verified satisfactory implementation of the corrective actions identified in the NOV
response during these earlier inspections. The inspector concluded that the actions taken by
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NYPA were satisfactory to resolve this violation. Violation 92-80-15C is closed.
6.3.1.4 (Closed) Violation mEl 333/92-80-15D)
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This pan of the violation indicated that NYPA's program for fire watch training and
implementation was less than adequate. In the response to the NOV, section III.A.5, NYPA
stated the following actions were taken to assure that fire watches are properly trained.
Interim retraining was conducted based on the identified concerns. Revised qualified fire
watch lists were issued. Job / task analyses were conducted for both hot-work and
compensatory fire watches. Written and performance training evaluations were implemented
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using job / task analyses. All fire watch personnel were retrained. Annual retraining is now
required for continued qualification. Supervisory oversight of fire protection training has
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been improved. The fire protection training was augmented and a second instructor was
added in support of the fire protection training program upgmde.
The corrective actions taken by NYPA to resolve this violation were reviewed during
previous inspections (reports 50-333/92-15, section 6.2.4 and 50-333/92-14, section 3.2.2)
The inspector verified satisfactory implementation of the corrective actions identified in the
NOV response during these earlier inspections. In addition, five compensatory fire watches
were interviewed on watch in the plant during this inspection. The inspector verified that the
watches knew their post responsibilities, including the actions to be taken in the event of a
fire. The inspector concluded that the actions taken by NYPA were satisfactory to resolve
this violation. Violation 92-80-15D is closed.
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6.3.1.5 (Closed) Violation (EEI 333/92-80-15E)
This part of the violation dealt with failure to develop and implement the license
requirements adequately for the fire brigade program. The weaknesses identified included
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lesson plans that were weak and had not been updated periodically, (e.g., lesson plans were
not performance based, were not updated to include the latest plant modifications, did not
include in plant hydrogen fires, did not include hazardous material confinement and control)
inadequate fire brigade drill program, fire brigade equipment poorly maintained, and fire
brigade drill performance weak.
In the response to the NOV, section III.A.2, NYPA stated fire protection training procedures
were upgraded to include: (1) periodic program assessments; (2) lesson plan approvals and
periodic review / validation; (3) brigade performance objectives; (4) brigade member
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qualification and disqualification; and (5)make-up and remedial training requirements.
Upgraded lesson plans were revised to link brigade performance objectives and to include
plant specific references where appropriate. Fire brigade drills, including backshift drills,
have demonstrated satisfactory performance.
The inspector reviewed the debrief notes from eight completed fire brigade drills that were
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conducted in the plant over the past year. The notes from four of the drills (April 21,1992,
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April 27,1992, October 19,1992 and November 18,1992) indicated that communications
between the brigade leader and individual brigade team members was less than adequate
during parts of the drills and suggested the need for portable radios to improve
communications. Fire brigade communications was evaluated by corporate fire protection
engineering during a previous inspection (50-333/92-14, section 6.9.3) and determined to be
satisfactory in light of recent improvements in the newly purchased SCBA masks equipped
with speaking diaphragms and other communication systems available. However, in
consideration of the problems identified during the drills, the Fire Protection Supervisor has
procured portable radios as an interim measure and site management has agreed to further
evaluate the use of portable radios for fire brigade communications.
The corrective actions taken by NYPA to resolve this violation were reviewed during
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previous inspections (reports 50-333/92-15, section 6.2.5 and 50-333/92-14, sections 6.7.1,
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6.8.2,6.9.3,6.9.4, and 8). The inspector verified satisfactory implementation of the
corrective actions identified in the NOV response during these earlier inspections. Based on
the above review, together with the reviews conducted during the earlier inspections, the
inspector concluded that the actions taken by NYPA were satisfactory to resolve this
violation. The inspector recognizes managements decision to review communications is a
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good initiative to improve the communications between fire brigade members. Violation 92-
80-15E is closed.
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6.3.2 Violation (EEI 333/92-80-06A. 06B. 06C. 06D)
This multi-part violation was reviewed during an earlier inspection (92-333/92-14) to verify
adequate corrective actions were developed by NYPA prior to plant startup. However, the
violation was not closed at that time. During this inspection, the inspector verified that the
corrective actions identified in NYPA's NOV response (JPN-92-063, dated October 15,
1992) were adequately implemented. The inspector did not review item 92-80-06B as this
part of the violation deals with inadequate suppression systems for the East and West cable
tunnels and upgrade of these systems were not complete at the time of the inspection.
6.3.2.1 (Closed) Violation (EEI 333/92-80-06A)
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This part of the violation dealt with failure to meet redundant train separation requirements
of 10 CFR 50, Appendix R, Section III.G for fire areas not requiring altemate shutdown
capability. In the response to the NOV, item IV.2, NYPA stated that the draft 1992 Safe
Shutdown Capability Reassessment identified modifications or evaluations that must be
installed or completed before FitzPatrick can be brought into full compliance with the
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requirements of Appendix R. Modifications to correct the identified deficiencies have been
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engineered and were in the process of being installed. Exemptions have been prepared,
submitted, and NRC approval received for those identified deficiencies that required
exemptions.
The corrective actions taken by NYPA to resolve this part of the violation wer.: reviewed
during a previous inspection (report 50-333/92-14, sections 2.6,3.1.1,3.1.6 and section 5 )
which addressed NYPA's 1992 Appendix R Reanalysis, the Appendix R Exemptions granted
in the NRC letter, dated September 10,1992, and the 43 Appendix R reanalysis open items
(Note: Appendix R reanalysis item AR-40 on the deicing heaters remains open, but it is not
discussed in items 92-80-06A, 06B, 06C, or 06D.) During this inspection, the inspector
verified that the corrective actions identified in NYPA's NOV response were implemented
adequately, including satisfactory installation of the required modifications. Violation
92-80-06A is closed.
6.3.2.2 (Closed) Violation (EEI 333/92-80-06C)
This part of the violation dealt with potential spurious operations or equipment failures that
do not meet the requirements of 10 CFR 50, Appendix R, Section III.L.7, identified by
NYPA's 1992 Appendix R Reanalysis. In the response to the NOV, item IV.3, NYPA
stated full compliance will be achieved by completing modifications to correct all deficiencies
currently identified. Exemptions have been prepared, submitted, and NRC approval received
for those identified deficiencies that required exemptions. The corrective actions taken by
NYPA to resolve this part of the violation were reviewed during a previous inspection (see
explanation provided above for violation EEI 333/92-80-06A). Violation 92-80-06C is
closed.
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6.3.2.3 (Closed) Violation mEI 333/92-80-06D)
This pan of the violation dealt with failure to adequately analyze the separation of safe
shutdown functions in the North cable tunnel and battery room corridor, and failure to
provide alternate shutdown capability per the requirements of 10 CFR 50, Appendix R,
Section III.G.3.a. In the response to the NOV, item IV.2, NYPA stated the draft 1992 Safe
Shutdown Capability Reassessment identified modifications or evaluations that must be
installed or completed before FitzPatrick can be brought into full compliance with the
rquirements of Appendix R. Modifications to correct the identified deficiencies have been
engineered and are in the process of being installed. Exemptions have been prepared,
submitted, and NRC approval received for those identified deficiencies that required
exemptions. The corredve actions taken by NYPA to resolve this part of the violation were
reviewed during a previous inspection (see explanation provided above for violation EEI
333/92-80-06A). Violation 92-80-06D is closed.
6.3.3 (Closed) Violation mEI 333/92-80-13)
This violation dealt with failure to provide adequate emergency lighting for access and egress
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routes to alternate safe shutdown equipment and provide adequate emergency lighting for an
operator to perform alternate safe shutdown functions as required by 10 CFR 50, Appendix
R,Section III.J. In the response to the NOV, item IV,4, NYPA stated access / egress routes
to and in the vicinity of safe shutdown equipment were walked down to determine the need
for additional emergency lights. Upon development of the draft operating procedures for
response to a fire, additional manual operator actions were identified. Locations of operator
actions were walked down to determine if any additional emergency lights were needed.
Modification packages were engineered to install emergency lights in the areas identified as
needing additional emergency lights. The corrective actions taken by NYPA to resolve this
violation were reviewed, in part, during a previous inspection (report 50-333/92-14, section
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6.2.6). During this inspection, the inspector verified that the corrective actions identified in
NYPA's NOV response were adequately implemented. In addition, the inspector toured the
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plant and verified correction of the specific deficiencies listed in inspection report 50-333/92-
80, section 2.4.3. This violation is closed.
6.3.4 (Open) Violation (EEI 333/92 4 0-14)
This violation dealt with failure to incorporate vendor recommended maintenance and testing
into the emergency lighting surveillance and test procedures to assure operability and
availability of emergency lighting units as required by 10.CFR 50, Appendix B, Criterion
III. The inspector was asked to review this item for closure during this inspection by the
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NYPA corporate fire protection engineering group. The inspector requested the vendor's
documentation for recommended maintenance and testing for the lighting units installed (i.e.,
Exide and Halophane) to verify applicable incorporation into FitzPatrick procedures. The
inspector determined that the FitzPatrick staff had not included all the vendor
recommendations in their procedures as identified in the original violation. Consequently,
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NYPA decided to reevaluate the corrective actions taken, to date, since all vendor
recommendations have not been incorporated into NYPA's procedures and technical
evaluations have not been prepared to justify variances. This violation remains open.
6.4
Followup of Fire Protection Items Completed After Plant Startup
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Background
NYPA committed to complete the following post startup actions in letter JPN-92-023, dated
May 27,1992. These items were previously tracked under URI 92-80-02. These items are
currently being tracked as Inspector Followup Items (IFI's).
6.4.1 (Closed) IFI 92-14-09. Item 2.3.3 Evaluate the Noise Irvels of the Evacuation Alarm
and the Fire Alarm in the Control Room and their Imoact on Control Room
Communication
This item was evaluated during a previous inspection as a diagnostic evaluation observation
(report 50-333/92-11, section 2.4, DEO. OPS.041). NYPA had measured the auditory signal
intensities of the fire, station, and evacuation alarms. Inspector review of NYPA's test
results (F-OP-63) in this previous report had concluded the noise levels were within the
guidelines of NUREG 0700. This item is closed.
6.4.2 (Closed) IFI 92-14-10. Item 2.3.4 Revise as Necessary the NYPA Nuclear Generation
Business Plan and/or the FitzPatrick Plant Results Imorovement Plan Based on the
Findines of the Overall Root Cause Analysis
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The inspector interviewed a senior site manager and reviewed the revisions made to the
Results Improvement Plan (RIP) based on the findings / corrective action recommendations
identified in the root cause analysis report of the Fire Protection Program problems (FPI-92-
215, dated March 6,1992, " Organizational and Programmatic Assessment of James A.
FitzPatrick Nuclear Power Plant Fire Protection Program"). The revision added a whole
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new section (012.0, Fire Protection Improvement Program) to the RIP. This section
incorporated approximately twenty-five action items identified in the root cause analysis not
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previously addressed in the RIP. The action items were categorized into three major areas
(i.e., Evaluate Design Basis, Revise Fire Protection Program and Procedures, and Other Fire
Protection Program Issues). Responsible individuals and target dates for completion were
also assigned for each of the action items. The inspector concluded that the actions taken to
revise the RIP were adequate. This item is closed.
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6.4.3 (closed) IFI 92-14-11. Item 2.3.6 Imorove Labeling on the Safe / Alternate Shutdown
Panels as Part of the Overall Labeling Program
The inspector reviewed the Design Equivalent Modification Form, D1-92-325, " Upgrade
Existing Control Panel Labels", and also JCM-92-0048, dated September 30,1992,
" Transmittal of Labels For Shutdown Panels 25RSP,25 ASP-1,25 ASP-2,25 ASP-3, and
02 ADS-071. The inspector also toured the plant and verified newly installed label
installations were adequate. This item is closed.
6.5
Followuo ofIEng Term (LT) Fire Protection Actions
6.5.1 (Open) URI 333/92-80-02
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In letter JPN-91-050, dated September 13, 1991, NYPA committed to complete a number of
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Iong Term (LT) Fire Protection actions. Inspection report 50-333/92-80 addressed these
long term items in section 2.2.2 as part of URI 333/92-80-02. The long term items (LT-1,
4, 7,13,17, and 20) listed below were closed based on reviews conducted during a previous
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inspection (92-14). Previously, these items were treated as short term prior to plant startup
items and duplicate the below listed long term post-startup items.
6.5.2 (Closed) Item II.F.1.a (LT-1) Fire Protection Procedure Revision
The corrective actions taken by NYPA to resolve this item were reviewed during a previous
inspection (report 50-333/92-14, section 6.7.1). During the previous inspection, the
inspectors reviewed a number of different procedures including Abnormal Operating
Procedures, AOP-28, AOP-43, AOP-58, and Work Activity Control Procedures, WACP-
10.1.10 (Control of Combustibles and Flammable Materials), WACP 10.1.33 (Hot Work
Permits), and Fire Watch Procedures. This previous report documented the review of
procedure revisions completed by NYPA to date and found them to be acceptable. However,
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additional procedure changes are anticipated as a result of an NFPA code compliance review
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NYPA has committed to complete in the future. In addition, the completion of any required
additional Fire Protection Procedure Revisions will be tracked and reviewed by the
verification of satisfactory completion of currently outstanding Fire Protection Program items
including: Inspection Followup Items 92-80, 2.1.1, 2.1.2, 2.2.2, 2.2.3, 2.2.4, 2.3.1, 2.3.2,
2.3.7; EEI 333/92-80-15F and 16; and URI 50-333/92-80-17. This item is closed.
6.5.3 (Closed) Item II.F.1.d (LT-4) Fire Barrier Reevaluation
The corrective actions taken by NYPA to resolve this item were reviewed during a previous
inspection (report 50-333/92-14, section 2.8). During the previous inspection, the inspectors
compared a selected sampling of installed seals to penetration seal evaluation forms and
found them to be accurately prepared. The accuracy of fire barrier penetration drawings was
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also verified through plant walkdowns. In addition, fire barrier penetration seal modification
procedures were reviewed and found to be acceptable. Finally, fire damper modification
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packages were reviewed and inspected in the plant and no deficiencies were noted. This item
is closed.
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6.5.4 (Closed) Item II.F.2.b (LT-7) Fire Penetration Oualification Reoort Review /Anoroval
The corrective actions taken by NYPA to resolve this item were reviewed during a previous
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inspection (report 50-333/92-14, section 2.8). See summary of previous inspection activities
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provided for item LT-4 above. This item is closed.
6.5.5 (Closed) item VIILF.2 (LT-13) Improve Checking of Design Documents
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The corrective actions taken by NYPA to resolve this item were reviewed during a previous
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inspection (report 50-333/92-14, sections 6.7.2 and 4.7). During the previous inspection, the
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inspectors reviewed Design Control Manual, DCM 13, Conduct of Design Engineering
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which was revised to provide fire protection reviews for all future modifications. The
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inspectors concluded during this inspection that the actions taken by NYPA were adequate to
resolve this matter. This item is closed.
6.5.6 (Closed) Item X.C.3 (LT-17) Full Fire BarTier Seal Insoections
The corrective actions taken by NYPA to resolve this item were reviewed during a previous
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inspection (report 50-333/92-14, section 2.8). See summary of previous inspection activities
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provided for item LT-4 above. This item is closed.
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6.5.7 (Closed) Item X.C.6 (LT-20) Identifv Ootimal Shutdown Eauipment List
The corrective actions taken by NYPA to resolve this item were reviewed during a previous
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inspection (report 50-333/92-14, section 6.1.2). During this previous inspection, the
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inspectors verified that NYPA had generated a safe shutdown list to identify the minimum
safe and alternate shutdown components. This item is closed.
7.0
SAFETY ASSESSMENT / QUALITY VERIFICATION (IP 71707,93702)
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7.1
Review of Licensee Event Reoorts (LERs) and Soecial Reoorts
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7.1.1 LER Review
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The following LERs were reviewed and found satisfactory:
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LER 92-30, Missed Hourly Roving Fire Watch Patrol.
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LER 92-49, Incomplete Scaled Radioactive Source leakage Surveillance Due to
Procedure Deficiency.
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LER 92-52, Roving Fire Watch Late Due to Personnel Error by Fire Watch
Personnel.
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LER 93-03, Non-Safety-Related Components Connected to the Drywell Nitrogen
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Header possibly affecting Long-Term Nitrogen Supply for ADS. This event was
reviewed in detail as documented in inspection report 93-04, section 7.1.
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LER 93-G4, Iow Intake level Scram. This event was reviewed in detail as
documented in inspection report 93-04, section 2.2.1.
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7.1.2 Review of LER 93-06. Inonerability of Fire Pumps
The event description in the LER states that the electric fire pump, 76 P-2, was declared
inoperable at 1820 on February 25 and the diesel fire pump, 76 P-1, was declared inoperable
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at 0207 on February 26 with appropriate Technical Specification (TS) action statements being
entered as each pump was declared inoperable. This differs from the chronology provided
via the Emergency Notification System on February 26 and facsimile transmission on March
1. The LER stated that these initial notifications were in error. However, inspector review
of the shift supervisors log revealed that the electric fire pump was declared inoperable at
1700 on February 26. An occurrence report (OR) was written at 1820 on February 25,
which first documented the problem with the electric fire, pump. Further engineering review
was requested and a formal determination of inoperability was made the following day. The
time of OR issuance was incorrectly used in the LER as the time inoperability was declared
and the TS action statement was entered. This error was not identified during NYPA's LER
review process. The inspector shared this information with NYPA representatives the week
of April 5,1993. During the weekly meeting with site management on April 12, NYPA
informed the inspectors that a supplemental LER to revise the incorrect information was
being prepared.
Incomplete and inaccurate information being provided to the NRC by NYPA was the subject
of an escalated enforcement action (No.92-033) documented by letter dated
September 15, 1992. Although the error in fire pump inoperability chronology was not
safety significant and was not considered willful based upon the inspector's review, the
incorrect information documented in LER 93-06 is a violation of 10 CFR 50.9
(VIO 93-06-02). Corrective actions taken by NYPA, as documented in their
October 15, 1992 response to the enforcement action were ineffective in preventing a
recurrence.
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7.2
Radiocraphy Review Followuo
Backcround
On December 2,3 and 4,1992 an inspection was performed by the NRC's ASNT Certir d
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Level III of radiographs contained in archival storage at FitzPatrick. This inspection resulted
in the issuance of eight violations under report 50-333/92-21. As a consequence of this
inspection, NYPA personnel conducted a review of radiographs produced at the plant since
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1983. In a letter, dated December 23,1992 (JPN-92-075), NYPA stated that 100% of all
Category I welds from 1983 to present had been reviewed. Funher, NYPA stated that this
100% review confirmed "that the welds at the FitzPatrick Plant are structurally sound." The
review process used by NYPA, in support of this statement, was examined by the NRC
level III on December 23,1992.
Subsequent to the above stated activities, NYPA undertook a program to create a new
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records keeping system for radiography. This included the use of a new label for each
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radiographic package that captured identifying data in a consistent manner. The information
recorded on the label, as a minimum was: line number, weld number, modification number,
work order, system identification, and date of exposure. During the December 1992
radiographic film review process, the decision to perform a 100% review of all Category I
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film was not effectively communicated to the personnel performing the review at FitzPatrick.
These personnel were working under the provisions stated in a draft of the letter of
December 23,1992, which stated that a sample of radiographs from the 1983-1984 time
period would be reviewed. Thus they chose a sample of 1983 radiographs and returned the
remainder of the 44 sets to permanent archival storage. It was not until the new record
keeping system was instituted that the omission was discovered. The 44 radiographic sets
were reviewed by a NYPA level III on March 17, 1993.
Inspector Followup
1
As a consequence of this discovery, an Adverse Quality Condition Report (AQCR 93-023)
was issued on March 18,1993. A complete search was undertaken of the entire film storage
area to determine if any other film might exist representing quality assurance category I
welds. The search turned up 11 sets of radiogrr.phs that were not part of the December 1992
,
review process. Five of these radiographic sets were for welds from 1989 that had been
separately filed by the NYPA Inservice Inspection department after they had reviewed the
welds. An additional six radiographic packages were discovered filed with the vendor film
of the component with which the field welds were associated. NYPA personnel involved in
the radiographic review process stated that they believed the film was misfiled because
someone believed that the pipe-to-pup piece weld was performed by the vendor at the time
the vendor welded the pup piece to both ends of the component. This was incorrect because
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the weld of the pup piece-to-pipe was a field modification. To assure that all the film
exposed during the period 1983 to present was captured, a review of all known work
requests and modification packages was compared with all radiographs in hand. This
comparison was favorable and NYPA concluded that all film was now captured.
Because every system modification that might affect the ISI program is reviewed by the ISI
engineer before the work begins, the misfiled film does not affect the ISI component
population upon which the program is based. Each weld entered into the ISI program is
assigned a unique identification after this review. This identification method is not used by
the modification process. Three welds were chosen from the list of ISI welds and the
radiographs pulled from the new filing system. In all three cases, the radiographs were
available and the documentation corresponded correctly.
]
In addition to the above review of program corrections, five radiographs from the 44
inadvertently returned to permanent archival storage were reviewed by the NRC Level III.
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The radiographs are for welds: 15-4"-WCL-1512-70, FW-7; 15-4"-WCL-151-39, FW-2; 15-
4"-WCL-151-70, FW-6; 15-6"-WCL-151-29, FW-2; and 15-4"-WCL-151-39, FW-1. At the
same time, the NRC Ixvel III reviewed five radiographs of the 34 originally reviewed by
NYPA for the 1983 time period. The radiographs are for welds: 03-8"-WR-902, WA-21,
03-8"-WR-902, WA-5; 03-10"-WR-902, WA-2; 03-8"-WR-902, WA-27; and 03-8"-WR-902,
WA-18. In all cases the film and welds met the standards prescribed.
i
The NRC level III inspector reviewed all five of the 1989 radiographic packages that had
been filed separately by the ISI inspection personnel and missed by the original December
1992 review program. The radiographs represented the following welds: 12-6"-WR-902A-1,
Weld 6-12-902; 12-B"-WR-902A-1, Weld 6-12-A; 12-6"-WR-902A-1, Weld 6-012-908
(#47); and 14-10"-W23-152-913, Weld 10-4-884A. These radiographs and the welds they
represent met the standards prescribed.
Two of the six radiographic packages for 1985, misfiled with vendor film, were reviewed by
the NRC Level III inspector. The two sets of film were chosen from line 10-20"-W20-1504-
42 which were associated with modification FI-82-033. Weld A-R had originally been
i
radiographed using a six exposure technique. Three of the exposures origirailly contained
rejectable indications (1-2,2-3,3-4) and were subsequently repaired; with 2-3 requiring two
repairs to achieve an acceptable weld. In the process of repair and acceptance, the original
radiographs of the weld section that was acceptable (0-1 and 4-0) were misplaced. A search
of the archival storage area did not turn up the missing radiographs. However, the original
radiographs interpretation report was in the package indicating acceptance of the sections. In
addition, the preservice inspection report was available for the final weld and indicated no
rejectable indications. While the inspector was on site, NYPA representatives concluded that
the reperformance of radiography for the missing portions of the weld would be in order to
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ensure the radiographic record from 1983 to present was complete. The NRC inspector was
shown a work order draft, written to perform this radiography during the next regularly
scheduled outage. The second weld from this line was W-J. The radiographic package
reviewed by the NRC Ixvel III inspector was found to be acceptable in all respects.
Review of Previously Identified Items
Details of the NYPA response to the eight violations of inspection report 50-333/92-21 w, :
1
reviewed by the inspector. The analysis of unfixed film was reviewed. NYPA's actions
involving archive checks appropriately resolved this issue. Violation 92-21-01 is closed.
The calibration procedure for the optical densitometer was reviewed. Supporting data
revealed that calibrations were now being performed in conformance with the applicable
standards. Violation 92-21-02 is closed.
The replacement film for 3"-SHP-902-6, FW10, was reviewed. The new radiographs were
found to be in conformance with the standards. Violation 92-21-03 is closed. Of the two
welds identified in violation 92-21-04, only WM-92-682, FW2 was a safety weld. This weld
is now identified as 10-16"-W20-302-15B, FW2 under the new uniform filing system. Two
repairs were required to produce an acceptable weld. The final set of radiographs was
reviewed by the NRC level III and found to be acceptable. Violation 92-21-04 is closed.
The new radiographs for: 10-24"-W20-302-11 A, Weld 24-10-991; 10-16"-WS-151-30A,
SW1; and weld 24-10-997 (now 998) on 10-24"-W20-302-11B, were reviewed by the NRC
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level III and found acceptable. Violations 92-21-05,06 and 07 are closed. As discussed
above, the licensee has undertaken a number of actions to correct the programmatic
radiography problems. These actions have been conservative, comprehensive and responsive
to the concerns identified. Violation 333/92-21-08 is closed.
8.0
MANAGEMENT MEETINGS
At periodic intervals during the course of this inspection, meetings were held with senior
facility management to discuss inspection scope and findings. In addition, at the end of the
period, the inspectors met with licensee representatives and summarized the scope and
findings of the inspection as they are described in this report. The licensee did not take issue
with any of the findings reviewed at this meeting.
On March 22,1993, a public meeting was held by NYPA and NRC management to discuss
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the licensee's self-assessment of their post-refueling outage startup. A copy of the slides
used at this meeting is included as Attachment 1.
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