ML20042B959

Request for OMB Review & Supporting Statement Re IE Bulletin,Alteration of Radiographs of Welds in Piping Subassemblies.Estimated Respondent Burden Is 2,768-h

ML20042B959
Person / Time
Issue date:	03/16/1982
From:	Donoghue D, Scott R NRC OFFICE OF ADMINISTRATION (ADM)
To:
Shared Package
ML20042B958	List: ML20042B957 ML20042B959
References
NUDOCS 8203290044
Download: ML20042B959 (12)

Text

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(Und:t th2 Pap:rwOrk R: duction Act and Exzcutiv2 Ordzt 12291) hep:rt:nt - R::d instructions (SF 83 A) before completing this OfficocfInform:lioncnd R:gulatory Affairs form. Submit th3 r: Quit:d numb 3r of copi:s of SF 83.t:gith:r Offics of M snag 1m:nt cnd Budg t Cith th] m:terial for which review is requested to:

Wa shington. D.C. 20503 1.Dep;rtment/ Agency and Bureau / Office originating request 3.Name(s) and telephone number (s) of person (s) who can best answer questions regarding request U S. Nuclear Reaulatory Corm 11ssion W. Mu114niv ( inliaop anac 2.6-dogst Agency / Bureau number (firstpart of 11-digit Treasury 4.3 dsgit functionit code fastpart of 11 digit Tier ury Account Account No.)

No.)

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9. T sti3 of inf ormatson Collection or Rulemaksng C. Is this a rulemaking stabmsssion under Secfwn 3504 ths of IE Bulletin, Alteration of Radiographs of P.L. 96 511 ? (Check one)

Welds in Piping Subassemblies R No (Sectim 3507 submission) 2 0 Yes.NPRM. Expected date of publication:

6. A.Is anyinformatson collection (reporting or recordkeepong) 3 0 Yes. final ru\\e. Enpected date of pubiacation:

involved? (Check one)

Effective date-1 R Yss and proposalis attached for review D. At what phase of rulemaking is this submission made?

2 0 Yss but proposalis not attached - skip to question D.

3 O No - skip to Question D.

1(X Not applicable f

B. Ar2 the respondents primarily educationalagencies or 2 C Maior rule, at NPRM stage inststutions oris the purpose related to Federal education 3 0 Major Final rufe for which no NPRM was pubfished prograrns ?

a.O Major Final rule.af ter publication of NPRM O Yss G No 5 O Nonmajor rule, at NPRM stage 6 O Nonmajor rule. at Final stage COMPLETE SH ADED PORTION IF INFORM ACN COLLECTION PROPOS Al.lS ATTACHED

7. Current (or former) OMB Number

8. Requested

12. Agency report form number (s).

Expiration Date

--~~ ~ '- ~~~~ '-~'~~~

_N/A N/A Expiration Date

13. Are respondents only Federalagencies?

mN/A O Yes Ot No

9. Is proposed information collection listed ;n

14. Type of request (Check one) th* Information collection budget?

O Yes' 3 No 1 O preliminary plan

10. Will this proposed information collection 2 Q new (notprevsously approved or erpired more than 6 months to exceed its intormation ago)

,,..c:uss the agency'sIfoWar 64f7Tf kWaitaTh yY6hN 5 die,v$i$rb' N#~W

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• '" cbtidtiori t2dget amendment request from agency head.)

e o extensson (adiustment to burden only)

11. Numb:r of report forms submitted for approval 5'OTxtensiYn'fn'o'ch'arig'e)

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NONE 6 0 *528'ement IP'*8 "hia 8 moa'h5) 15.

16. Classification of Change in Burden (explain in supporting statement) e Acceonmate s're of umverse t.t sermos l e

N/A No.of Responses No.of Reporting Hours Cost to the Public h sissof umeie

a. in inventory S

n c Enumsted number of

b. As proposed 16 9;76R S

rIlponoent3or r"o'N o' o Y"'

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c. Dif ference (b-a)

S 16 9;7gR

'd.Repo,1:ennueu ey ncn Explanation of difference (indicate as many as apply) r rnooncent r. rem 2s1 1.6 Adjustments 3g l+-

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c.Tret onnust enooases

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d. Correction-error A

horm thes1548 4

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e. Correction-reestimate -

f. E stemited e ve'a ge

+

+

+

rumeee or hours

f. Change lh use r

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Program changes

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l' 'e E stimated totel hour s ognnzei suroen en

g. Increase

+

16

+

F6 cil Y'er 2,768 4g terem :5e r tsfl 2 '/68

h. Decrease

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i l~ 8203290044 820316 Standard Form 83 (Rev. 3-81) i PDR ORQ EUSOMB For Use Beginning 4/1/81 l

PDR

17. Abstr:ct-N:eds and Uses (50 words er1:ss) lernedial actions.ffected applicants are to review suspect radiographs and reportifindings r

.18. R:l';t:d report f orm(s) (give OMB number (s). lRCN(s).

20. Catalog ot Federal Domestic Assistance Program Number int:rn:I a gency report form number (s) or symbol (s))

Nlb Draft iE Bulletin Addressing Problem Associated 21.sman busness or organization O Yes G No with Alteration of RadiogrJohs of Welds 19.Typ3 of affected public (Check as many as apply)

22. Type of activity of affected public-indicate 3 digit Standard industrial Classification (SIC) code (s) (up to 10) - if over 1 O individuals orhouseholds

10. check O Multipie or O All 2 O state orlocalgovernments 3 O f rms a Q businesses or otherinstitutions (except farms,)

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23. Bri:t description of affected public le g.." retail grocery stores'."" State education agencies."" households in 50 largest SMSAs")

Nuclear plant sites that have received fabricated piping assemblies from AP&E.

24. Purpose (Check as many as apply. Itmore than one. indicate

26. Collection method (Check as many as apply) picdcminant by an asterisk) 1 Q mail self-administered l

I 1 O epplication for benefits 2 O other self-administered 2 O program evaluation 30 telephoneinterview h~

3 0 generalpurposa statistics 4 O personalinterview 4 3 regulatory or cornpliance 50 recordkeeping requirement:

5 O program planning or management Required retention period; years _

6 0 o'her-describe:

6 0 research l 25 Frcauencyof Use

27. Collection agent (Check one) 1 Q Nontecurring 1 Ekrequesting Department / Agency Recurring (check as many as apply) 2 O other FederalDepartment/ Agency 2 O on occasion 6O semiannually 3 O private contr, actor 3 O weekly 70 annually 4 0 recordkeeping requirement

-r 4 0 m entnty 80 biennially 5 O other-describe:

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5 0 quarterly 90 other-describe:

28 Authcrity for agency for information collection or

30. Do you promise confidentiality?

rul2 making-indicate statute, regulation, judicial decree.

(/I yes, explain basis for pledge

' Win'supportingstatemeHPihW*~5i*D Yes

• ckNo W_ ' W

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Atomic Energy Act of 1954 31.Will the proposed infor,mation collection create a new or "bec'or6e psrt'bf 3n' existing PHvac'y Act'sys'ters of ricords? '

29 Respondent's obingation to reply (Check as manyas apply)

(If yes. attach FederalRegister notice orproposeddraft of notice.)

O Yes at No 1 O voluntary 2 O reovired to obtain or retain benefit

32. Cost to Federal Government of 3 g mandatory-cite statute.not CFR (attach copy of information collection or rulemaking s 30.400 statutory authority) l I

COMPLETE ITEMS 33 THRU 35 ONLY IF RULEM AKING SUBMISSION j

33 Compliance costs to the public i 34. is there a regulatory impact

35. ls there a statutory or judicial analysis attached?

deadline affecting issuance?

• 5 0 Yes O No O Yes. Enter date.

O No l

CERTIFIC ATION BY AUTHORIZED OFFICI ALS SUBMITTING REQUEST-We certify that the information collection or rulemaking submitted for revisw is necessary for the proper performance of the a;;ency's f unctions.that the proposal represents the minimum public burden and Federat Cost consist:nt with need. and is consistent with applicable OMB and agency policy directives. Signature and title of:

l tresioviNo Potecv orriciat rosi aGENcv DATE susuit tiho orricial caTE bC Ue F6&

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DanielJI)Donoghue R. Stephen Scott

Supporting Statement for ZE Bulletin on Alteration of Radiographs of Welds in Piping Subassemblies

1. ' Justification

( i.)

An applicant for a nuclear power plant operating license notified the NRC of finding alterations to certain radio-graphs of 21 shop welds D. M..ing subassemblies supplied by Associated Piping and Engineering Corporation (AP&E) of Compton, California.

The alterations consisted of artifi-cial enhancement of the ASME Code specified penetrameter 4T-Hole image.

This appeared to have been accomplished in one of thrre ways, (1) touch up with a soft lead pencil, (2) scribed or scratched with a sharp object or (3) inden-tion with a sharp object.

These forms of enhancement are very difficult to detect by normal film interpretation techniques (i.e., subdued background lighting).

However, utilizing direct overhead lighting the alterations may be detected by close inspection of the film surface reflections as the film is being manipulated at various oblique angles to the observer.

The subsequent NRC investigation determined that:

(1) radio-graphs had been altered on occasion by one Level II inter-pretor over a period of approximately eight years prior to the date of this inspection, (2) the alter'ations had been limited to the set of radiographs of welds submitted for customer review and approval, and (3) that a number of nuclear plant sites have recei';ed fabricated piping assemblies from AP&E and the radiographs may have also been altered.

.r.

A tutal of 16 nuclear power plant units at ten different sites may be affected.

None of these plants are yet opera-ting, but several of them are scheduled to be issued an operating license within two'-(2) months.

The Office of Inspection and Enforcement of the Nuclear Regulatory Commission is issuing a bulletin to the poten-tially affected plants.

The bulletin requires the appli-cant's to review all the suspect radiographs to ascertain the acceptability of the affected welds in accordance with the applicable ASME Section III Code requirements, and to ' provide a report which describes the findings and remedial actions.

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The urgency for action is based on the potential safety significance of initiating operation at affected nuclear power plants before resolving questionable weld radiographs.

Resolution of this issue is required before a determination can be made that the affected facility has been constructed -

substantially in accordance with NRC requirements and the application.

(ii)

See above.

(iii)

There is no other source for the data.

(iv)'

Not applicable.

2.

Description of Survey Plan i

(i)

A total of 10 applicants for nuclear power plant licenses are

' required to respond. The response is,to cover 16 individual units.

(ii)

The respondents that were selected.are -those that have piping assemblies fabricated by the company who employed the individual who has been found to be altering the radiographs.

(iii)

Not applicable.

(iv)

Not applicable.

3..

Tabulation and Publication Plans There are no current plans for publication of the data obtained.

4.

Time Schedule for Data Collection and Publication (i)

The time schedule is outlined in the bulletin.

All the respondents must respond within 120 days.

All corrective actions must be completed prior to issuance of an operating li. cense.

Those applicants for nuclear plants that are scheduled to receive an operating license within two (2) months ~

would therefore be required to respond sooner than 120 days.

(ii)

There are no plans to publish the results.

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5.

Consultations Outside the Agency l

An investigation of Associated Piping and Engineering Corporation was conducted.

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3-6.

Estimate of Respondent Reporting Burden

.i

~ The total effort of reviewing the suspect radiographs, evaluating the results, and reporting to the NRC is estimated to be one person-month per individual nuclear unit or a total of 16 About one-sixth of this effort (about 2.5 person-months) person-months.

is estimated to be required for reporting the results. The total burden in hours is 2,768.

7.

Sensitive Questions Not applicable.

8.

Estimate of Cost to Federal Government i'

Prepara-tion of the bulletin, including obtaining of all necessary clearances, required about three person-weeks of effort.

It is estimated that about one person-week of review cffort will be required for each nuclear unit for a total of 16 persoi-weeks of review effort.

Therefore, '

the total government effort is estimated to be 19 person-weeks and a total cost of,$30,400.

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551N5 Ns.:

6820 Accession No.:

B202041110 IEB 82-UNITED STATES

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NUCLEAR REGULATORY COMMISSION 0FFICE OF INSPECTION AND ENFORCEMENT WASHINGTON, O.C.

20555

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March

', 1982 Draft IE Bulletin:

ALTERATION OF RADIOGRAPikS OF i1ELOS IN PIPING SUBASSE Description of Circumstances:

On October 19, 1981 Washington Public Power Supply System (WPPSS) notified 'th'e l'

URC of finding, alterations to certain radiographs of 21 shop welds in piping

' subassemblies supplied to their WNP-Unit 3 by Associated Piping and Engineering

- g Corpcration ( AP&E) of Compton, California.

Further. examination of essentially, all AP&E radiographs previously sent to the site iden.tified alterations on 14 additional radiographs associated wi't' eight' welds in Class I stainless steel h

p'oing of less than i-inch wall thickness.

All affected' 29 welds in the thin

. wall piping were reexamined radiographically in accordance with the ASME Code.

No evidence. of unacceptable weld quality was identified..

The alterations consisted of artificial enhancement of the ASME Code specified penetrameter 4T-Hole image.

This appeared to have been accomplishe'd in one of S

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March

, 1982 i

Page 2 of three ways, (1) touch up with a soft lead pencil, (2) scribed or scratched with a sharp object or (3) indention with a sharp object.

These forms of enhancement are very difficult to detect by nonnal film interpretation techniques (i.e.,

subduedbackgroundlighting).

However, utilizing direct oyerhead lighting the alterations may be detected by close inspection of the film surface reflections as the film is being manipulated at virious oblique angles to the observer.

7 Following the above discovery, an inspection / investigation was made at AP&E by the NRC Region IV staff in December 7-11, 1981.

Th'is review established th.e

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following:

aD 1

1.

That radiographs had been altered on occasion by one. Level II interpretor over a period of approximately eight years prior tb the date of this V

i n,spection.

2.

The alterations had been limited to the set of radiogiaphs of welds submitted for customer review and approval.

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3.

The alterations involved welds associated with pipe wall thickness of less than i-inch and utilizing isotope radiography techniques and a number 10 or 12 penetrameter.

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Radiograph sets retained in AP&E file for WPPSS' Unit 2 con' ained t

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unaltered radiographs which did not exhibit the code required 2-4T pe:

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'i sc sensitivity.

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That a number of nuclear plant sites have received fabricated piping 5.

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Jj assemblies from AP&E which may have similar discrepancies as mentions above.

The affected sites are listed in Table I..

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. ASME Section III Code P.ules, Articles NB-5000 and NC-5000, requires weld quality acceptance of Class 1 and 2 piping be evaluated on the In radiography examination, meaningful interpretad

.k bases of radiography.

S,'J weld quality is dependent on utilizat' ion of a radiographic technique of q j

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sensitivity as measured by the penetrameter image indicators.

The adequ[

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_ n[h technique sensitivity is confirmed by the ability to visibly discern,the app:apriate T-hole images of the penetrameter when evaluating the radiogg weld quality in accordance with the governing code rules.

Radiographswf have had penettameter image quality indicators artificially enhanced by (

methods discussed abcve violate ASME Code requirements.

Accordingl'y,th following actions are necessary to independently reverify.that th'e examined welds of these particular shop fabricated subassemblies.a e acceptable for pi, ant service.

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Action to be Taken by Aoplicants For An Operating License and Holdars of Active Contruction Permits (Group 1, Table 1):

Determine on the basis of a 100 percent r'eview of radiograph sets 1.

representing the shop fabricated subassemblies provided by AP&E, whether the applicable ASME Code penetrameter s,ensitivity (2-2T, or 2-4T as required) is unaltered, and clearly? discernible, and that acceptable weld quality is' demons.trated.

In those cases where the specified penetrameter sensitivity is not 2.

discernible or is apparently enhanced in any manner,' as by the methods discussed, weld quality interpretation may be based on the ' equivalent For or higher penetrameter sensitivity discernible on the film sets.

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example, for those radiograph se'ts for which the required 2-4T penetra-meter sensitivity is not discernible, or found artificially enhanced on

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visual inspection, film interpretation of weld quality may be based on M

the presence of discernible 2-2T, or 2-1T sensitivity exhibited by the radiog raphs'.

Where conformance with Item 1 and 2 cannot be satisfied, appropriate 3.

steps shall be taken to assure the acceptability of the affected welds in accordance with the applicable ASME Section III Code requirements in effect for plant construction.

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Page 5 cf t

4 The above actions are to be completed prior to issu,ance of an OL or

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within 90 days of receipt of this bulletin, whichever occurs first.

All quality assurance records reflecting the review findings and disposition of discrepancies identified shall be maintained and ava'ilable for NRC review.

3,.

5.

A written report describing ~the fi,ndings and corrective actions taken or scheduled, signed under oath or affirmation under provisions of Secti'on 182a, Atcmic Energy Act of 1954, shall be submitted within 3cr 45 days after completion of Items 1 thru 4 tc the Regional Administrator of the appropriate NRC Regional 0'ffice.

A copy of the report is to be forwarded to'the Director, Office of Inspection and Enforcement, NRC, Washington, D.C.

.20555.

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' Actions to be Taken by Holders of Inactive Construction' Permits or Construction Permit Applications Cancelled or Withdrawn (Group 2; Table-1):

1.

For information only.

2. - In the event of transfer, sale, or other consignment of the subject piping subassemblies toanother nuclear plant site is contem-plated, both the NRC and recipient permit h"61 der, or license'e, are to be notified of the disposition of,said subassemblies under provisions of 10 CFR Part 21 regulations.

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This request f or information was approved by GA0 under.a+L'...ket clearance o

numberROS"'w$ichcxpirms

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ab;.

1333.

Comments on burden and dupli-cation should be directed to the Office of Management and Budget, Room 3201, New Executive Office Building, Washington, D.C.

20503.

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Attachments:

1.

Table 1 2.

Previously issued ~1E Bulletins r.

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TABLE 1 J

SITES WITH PIPING ASSEMBLIES FROM AP&E Group 1 Group 2 Grand Gulf, Units 1&2 Bailly Unit 1 LaSalle, Units 1&2 Black Fox Units 1&2 River Bend Units 1&2 Hartsville Clinton, Units 1&2 Phipps Bend Shoreham Limerick, Units 1&2 WPPSS-2 Nine Mile Point 2 Hope Creek Units 1&2 Allens Creek, Unit 1 m

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NUCIFAP REGUIATOBY COMMISSICE WASHINGTON, E. C., 20555 CN 02/12/P2, YOU RE00ESTEE APPROVAL OF THE FOLLCWI b G INFOBE A11CN COLI EC11CN:

7I1LE: CFDERS TC IICEhSEES ON BEF SCRAE EISCHAFGE VCIUME SYSTER AGENCY FCRE NCS.:

IN ACCCFTANCE W 17 Il THE P APERWOR K REDUCTICN AC1, WE EAVE TAFEN 1HE FCIIChING ACT IO N C N 1111 S IETCEMATICE COLLECTICE:

AFF"0VEI F0F USF T ERO U G il 12/31/82. OMD NC. 3150-0083.

11!IS NUMEFR AEE EXFIRATICN DATE EUST APPEAR Ih 11!E ESPER E I Gill-H A N C CCFlEF OF TFE FIFST FAGE CE THE PEFCRT FCFE OR Til E FIFS7 EAGE GE THE FEGULATICS, PANUAL, CF OT!!EF TOC U.* E NT INCORP0 FATING THE INFOEMATICN CCLIECTION UKLESS OTHER INSTRUC11CNS AFE IN "REMAPKS" BELOW.

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RESPCESES FEE 0FilNG HOUFS FFFVICUS STATUS 0

C N7W STA10S 14 4,75C EIFFEFFNCF 14 4,75C EXELANATION CF EIFFFRENCF:

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&a NCTICE CF CFFICE CF RANAGEFENT ANE EUEGET A C 1 1,0 b PAGI 2 CPP NC. 3150-0081 1C DATE THIS FISCAL YEAF YOU !! A V E SUDEIT1EC 2 REQUESTS, F0F CCNTINEEE USF OF A FORM, EllIC H WERE SUEMITIEE LESS 1HAN 45 EAYS BEFCFE SCHECULFD FXPIRATION.

CMP EXPECTS REQUESTS TO EE SLBMITTEE A1 LEAST 45 DAYS PFFORF SCHECUIEC EXPIRATICN.

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hRC TS CPDEPTNG IICENSEFS TO PROVIDE DATA ON BWE SCFAM DISCHAEGE SYS11E IN ORDEF 1C ASSFSS illE IEFACT OF SAFE 7Y.

ALIOW ANC E LE1TFF: NC FUNCTICE: ENEFGY IEFCRFATICN, POIICY, ANE SEGUIATION CN PLAK: NC EXCEED EUDGET: hC 3 5 C4 (11) : b/A NC. OF F0FMS: 1 USE: PUBLIC RECUEST: bE6 RFSPONDFNTS: 14 PESPONSES: 14 HCUBS: 4,15C AEFEC1EE FUBIIC: ECES/It.S1 SPALL EUSINESS: NC AC1IVITY 1YPE: 483 FUFFOSF: REG /COMF FEEOUE!CY: SNCI COILFCTICF 9 F1!!C D : MAIL S/A RETFMTICN:

COLLECTION AGENT-RQSTNG DF1/AGC)

CCEFIEENTIAIIII: NO CCPPULSCRY S1A1CS: PECD FCR BEN FEDFFAL COST: K176,000 PUBLIC CCSI:

FEVTEEFP: JEFFEFSCN B.

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AC1 ION

!AUTilCDIZING CEFICIAI

!111LE: EEFUTY AEElb1STRA1CE!IATE lAFFROVEE EY:

!/S/NA1 DANIEL SCURRY FCR!CEFICE CI INF0EEATICN IC2/26/82

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!ANE FEGUIA10RY AFFAIHs

.IMEORTANT: EECAUSE THIS INFORMATION CCIIECTICN HAS EEEN AFEFCVED, PLEASE SENE l 1 0 Tile 0. M. E. AS SCON AS AV AILA ELE: ONE COPY CF TIIE FINAL FBIb1ED (CF C1BEEWISE

! F.F FRO EUC E E) FEr0R1 FCRM, CR REPCFTING CR BECCFCKEEFING RECEIDEMENT, TFASSMITIAL lIFTTER, INSTRUCTIONS, ANE ANY DCCUMENT EEING SEhT 1C EACH EESFCNDENI.

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