ML19345B716
| ML19345B716 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 10/15/1980 |
| From: | Clayton F ALABAMA POWER CO. |
| To: | Murphy C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML19345B715 | List: |
| References | |
| NUDOCS 8012020397 | |
| Download: ML19345B716 (2) | |
Text
-.
Atbama Prwer Ccmpany 6,
600 North 18th Street 8
P:st Offica Box 2641 Birminghtm. Atbama 35291
.:,o..r' Telephone 205 25(,-1000 F. L. CLAYTON, JR.
Alabama Power Senior %ce President
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,) g. 56 the southem elecinc system October 15, 1980 J. M. Farley Nuclear Plant NRC Inspection of August 25-27, 1980 Mr. C. E. Murphy
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U. S. Nuclear Regulatory Commission Region 11 101 Marietta Street, N.W.
Suite 3100 Atlanta, Georgia 30303
Dear Mr. Murphy:
RE: RII:BRC 50-364/80-33 This letter refers to the apparent deficiency identified in the sub-ject inspection report which states:
"As required by Criterion V of Appendix B to 10CFR50 and imple-mented by Paragraph 17.2.5 of the FSAR, Activities affecting quality shall be prescribed by documented instructions, proce-dures, drawings....and shall be accomplished in accordance with these instructions, procedures, and drawings." Paragraph 6.9.4.1 of Farley General Maintenance Procedure FNP-0-GMP-51 (The applicable procedure for radiographic inspection of pipe welds) requires that the firm density through the area of interest not be more than 30 percent darker than the density through the penetrameter. For IE Bulletin 79-13, the area of interest is identified as the weld and two base material thicknesses on either side of the weld.
Contrary to the above, on August 25, 1980, for Weld C-1 radiographed to meet IEB 79-13, the film density through the base material adja-cent to the weld was greater than 30 percent darker than the density through the darkest penetrameter."
RESPONSE
Alabama Power Company wishes to take exception to this deficiency.
It is our opinion that the -15% + 30% density tolerance allowable by the ASME Code and FNP-0-GMP-51 is intended to mean the density in the general weld area.
- The portion of the film for Weld C-1 which is in question was in effect 0.3 greater than the tolerance allowed; however, this density 8 012020g g ErICLAL c&y
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s Mr. C. E. Murphy Page 2 October 15, 1980 was in the area of a discontinuity undercut. Discontinuities such as slag, lack of fusion, tungsten inclusions, porosity, cracks and under-cutting are revealed on radiographs entirely by their density variance from that of the general weld area density with the degree of variance depending upon the severity of the discontinuities. Therefore, a density reading taken directly on a discontinuity image is not indicative of the general weld area. The radiograph in question has a IT sensitivity with a maximum density of approximately 3.8 and all areas of the radiograph are interpretable for the purpose of the bulletin. The radiograph has been read by two Alabama Power Level III inspectors and we have discussed this problem with Level III inspectors employed by Westinghouse and Peabody.
All of these inspectors concur that the density tolerance allowed by the ASME Code ana FNP-0-CMP-51 applies to general weld area. Therefore, the film for Weld C-1 is an acceptable and accurate record.
The information contained in this letter is not considered to be of a proprietary nature.
Sincerely yours, F.
. Clayton, Jr.
FLCJr/JRC:bhj e.
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