ML19318C321

Responds to NRC 800527 Ltr Re Violation Noted in IE Insp Rept 50-412/80-04.Corrective Actions:Nine Welds Were re- Radiographed & Manually Processed.Machine Will Not Be Utilized on Film Applicable to ASME Section III Welds

ML19318C321
Person / Time
Site:	Beaver Valley
Issue date:	06/25/1980
From:	Woolever E DUQUESNE LIGHT CO.
To:	Robert Carlson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
NUDOCS 8007010348
Download: ML19318C321 (6)

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' i, (412) 471-4300 435 Sixth Avenue Pittsburgh, Pennsylvania 15219 June 25, 1980 United States Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406 ATTENTION: Mr. Robert T. Carlson, Chief Facility Construction and Engineering Support Branch

SUBJECT:

Beaver Valley Power Station Unit No. 2 Docket No. 50-412 USNRC IE Inspection Report No. 50-412/80-04 Gentlemen:

This is in response to the item of infraction cited in Inspection Report No. 50-412/80-04 and listed in Appendix A

.(Notice of Violation) attached to your letter to Mr. E. J. Woolever dated May 27, 1980.

NRC VIOLATION 10 CFR 50, Appendix B, Criterion IX, states, in part, that "... special processes, including... nondestructive testing are controlled and accomplished...in accordance with applicable codes. . . . "

The Beaver Valley Power Station PSAR, Section 17, paragraph 17.2.1.9A, also states, in part, that:

... nondestructive testing (be) controlled and accomplished...in accordance with applicable codes...."

The Specification 2BVS-920, Field Fabrication and Erection of Piping, ASME III Class 1, 2, and 3, requires that: ...These code class 1, 2, and 3 piping systems shall be designed, fabricated, installed, tested, and inspected in accordance with ASME III (1971 edition)."

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~4 ,Mr. Robert T. Caricon,' Chief Pcga 2 June 25, 1980

• 6 The-ASME III Code, Appendix IX, paragraph IX-3340, requires that: "The manufacturer shall record on a review form the interpretation and disposition'of each film."

Contrary to the above, -a review of radiographic film on April 19, 1980, for safety related pipe welds 2-RSS-021-F02, F04, F05, F07 and 2-RSS-062-F06,. disclosed indications which had not been interpreted, dispositioned, and recorded on the review form.

This item is an infraction.

RESPONSE

Resulting from the Infraction reported above, the nine ( 9.).

welds referenced in the Inspection Report were re-radiographed. The results of our re-radiography are shown in the table below, which also includes a summary of the Inspector 's findings reported during Audit 50-412/80-04.

WELD INSPECTOR'S COMMENT SQtMARY RE-RADIOGRAPHY MD*3 ER ON ORIGINAL RADIOGRAPHY RESULTS REMARXS 2-RS S-0 21-F0 2 Linear Indication Accept original condition an artifact 2-RSS-021-F03* Ncne Reject 1/8" U'I*

2/10" 2-RSS-021-F04 Linear Indication Accept original conditicn Poor Processing ,

an artifact 2-RSS-021-F05' Linear Indication Reject 1/8 L.O.F.

1/8 2-RSS-021-F06 None Accept --

2-RSS-021-F07 Porosity (Not Disp.)

• • Accept Acceptable - Porosity-in 2 areas

. Acceptable - Slag -

Overlay 2-RSS-021-F08 None Accept --

2-RSS-062-F06 Rounded Tail Indication Rej ect" L.O.F. in overlay in Overlay NED 46237 issued 2-CSS-078-F02" None Reject L.O.F. 1/16*

Abbreviations : U.I. Unconsumed Insert L.O.F.

. . . . . _ . = . Lack of Fusion The differences between the two sets of results can generally be attributed to film processing problems affecting the original film, confirming the Inspector's statements made at the Inspection exit meeting.

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IMr. Rob 0rt T. Cariron,- Chinf l PEgd 3 June 25,.1980 .

4 The result marked "**" relates to an'O.D.-pipe weld overlay

. applied by our fabricator. -This defect has been subject to an N&D, #6237.

The films and reports of - the rejected welds, marked "*",

had not been subject to. review by the NDE- Supervisor or ~

Level III NDE Examiner and not distributed. to the piping j installer at the time of the ' Inspector's . review. -We i 1

recognize that neither our procedures or report forms-indicated that such a review was required. . The review by the NDE Supervisor or Level III NDE Examiner had been applied as a supervisory action. As a temporary measure, l

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a written instruction was issued, April 23, 1980, to the NDE Section, formalizing the film review.

In order to establish the extent of the problems revealed by the Inspection, a review of previous radiography and associated reports was initiated. The time period selected for this review was from August 1,.1979 to ,

May 15, 1980. This time period was considered appropriate as immediately prior to August 1, 1979, the NDE Section had radiographed approximately sixty (60) welds. The radiographs and reports of these welds were subjected to detailed review by two (2) Inspectors and two (2) t independent Level III Examiners , with' no adverse comments reference film quality, processing and interpretation.

Approximately one thousand six hundred (1,600) radiographs covering one hundred sixteen (116) completed weld joints, thirty-four (34) repairs, nine (9) intermediate examinations, and two (2) defect removal verifications were reviewed for film processing quality and interpretation. From this review one previously accepted field weld joint (2 SIS.005.F15) was considered to be rejectable. The indication was subject to discussion and differences of opinion as to its relevancy, and the area in question-was re-radiographed. The differences of 1 opinion 'persis ted; the indication, _ however, was finally j described as a " partially unconsumed insert 5/16" long",

! and N&D #6242 was issued. The review did establish, i however, that acceptable indications had not always been included in the radiographic reports.

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Mr. Robert T. Carlson, Chief Pcgo 4

'Jun3 25, 1980 .

9 The defect associated with the weld overlay adjacent to Field Weld 2-RSS-062-F06 was applied by our pipe f abricator.

In- view of this problem, our review included an examination of weld overlay, visible on our radiographs of the field weld joints. A total of approximately one hundred sixty -

(160) radiographs covering a further seventy-four _(74) areas adjacent to the weld joints were reviewed for any questionable indications. Within the limitations of this review, no unacceptable indications were found. As the radiographs of record for the . weld overlays are held by the '

fabricator, Power Piping Co. , they were instructed to review their original radiographs of these areas. This review was applied to one hundred forty-one (141) weld

' build-up areas that had been welded during the last fourteen (14) months. They report no unacceptable defects have been found. _

An investigation was initiated with reference to the unacceptable quality of film resulting from film processing.

It was established that the problem was directly related to the automatic film processor. The machine had performed satisfactorily when applied to a certain type of film, but gave unsatisfactory results on the type of film used for ASME Section III, Division 1 work. It was also established that the radiographs of the nine (9) welds reviewed by the Inspector were the first batch of ASME Section III, Division 1 weld radiographs processed by the automatic film processor. ,

CONCLUSIONS Our conclusions from these reviews and investigation are that the unacceptable film quality and incorrect inter-pretation was limited to the films available in the laboratory at the time of the inspection, with one exception. With reference to Weld 2 SIS.005.F15, we consider the . differences of opinion as to the relevancy of the defect to be understandable, and we also consider this type of nonconformance does not indicate a breakdown of our-interpretation standards during the time frame under review.

There was no clear directive on action to be taken by NDE parsonnel when indications were observed outside the area cf the field weld joint being examined. The weld overlay defect is considered as an isolated instance.

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Mr. Robert T. Carl on, Chi @f PegD 5 . . ,

June'25, 1980 .

l There was no formal evaluation of Interpreter's peformance or clear instruction relative to the reporting ,

of' acceptable indications.  !

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'With reference to the film processing problems, ,the automatic processor had not been used previously for this class of work.  ;

CORRECTIVE ACTION The batch of ASME Section III, Division 1 radiographs originally processed by the automatic processing machine have been re-radiographed and manually processed. 'Until the problem of the automatic processing machine is resolved, the machine will not be utilized on film applicable to ASME Section III, Division 1 welds. . . .

We have added a "Section V" to our Site Quality Control NDE Manual, entitled "NDE/ ADMIN", and issued a new procedure, "NDE/ ADMIN-1", entitled " Interpretation and' Review -

Radiographic Film / Reports", Effective Date, May 19, 1980.

This procedure:

a) specifies the requirements for the initial interpretation, secondary review and additional review by the NDE Level III Examiner; b) includes instructions for the reporting of acceptable discontinuities and artifacts as well as those interpreted as unacceptable; c) institutes a system for a continuing review of Inte rpreter 's performance, including appropriate additional instruction when needed; and d) includes instructions for the action to be taken when indications are noted in the weld overlay .

as2a revealed by radiography performed on our field weld joints.

The applicable staff have been instructed in the require-ments of the above procedure, and with its implementation we consider that the problems revealed will not re-occur.

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Mr. Robtrt T. Caricon,-l Chief Pega 6 Junn 25, 1980 .

The condition of the two welds subject to N&D's #6237 and

1. 6242 will be corrected to conform to the applicable code.

However, the original condition of the welds, although in v:'olation , is not considered to have a safety implication.

DUQUESNE LIGHT COMPANY By -

E. J(/ Woolever Vice President i

cc: Dr. V. Stello (15) f l

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