ML20054M532

Forwards Proposed IE Bulletin Re Alteration of Radiographs of Welds in Piping Subassemblies for Review & Comments. Informs That Comments Received by 820309 Considered in Preparation of Final Revision

ML20054M532
Person / Time
Issue date:	03/04/1982
From:	Jordan E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:	Arlotto G, Minogue R, Novak T Office of Nuclear Reactor Regulation, NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES)
Shared Package
ML20054M514	List: ML20054M513 ML20054M523 ML20054M532
References
NUDOCS 8207130557
Download: ML20054M532 (9)

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UhliED STATES NUCLEAR REGULATORY COMMISSION 3

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,E WASHINGTON, D. C. 20555

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1 MEMORANDUM FOR:

T. M. Novak, Assistant Director, OP, DL, NRR i

R. B. Minogue, Director, RES G. A. Arlotto, Director, DET, RES H. S. Bassett, Acting Director, MPA C. Michelson, Director, AEOD j

W. J. Besaw, Director, TIDC, ADM

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E. L. Jordan, Director, EQA, IE J. M. Taylor, Director, RP, IE R. F. Heishman, Acting Chief, RCB, RP, IE I

L. I. Cobb, Director., FFMS, IE R. C. Haynes, Regional Administrator, Region I J. P. O'Reilly, Regional Administrator, Region II J. G. Keppler, Regional Administrator, Region III J. T. Collins, Regional Administrator, Region IV R. H. Engelken, Regional Administrator, Region V FROM:

Edward L. Jordan, Director, Division of Engineering and Quality Assurance, IE

SUBJECT:

IE DRAFT BULLETIN - ALTERATION OF RADIOGRAPHS OF WEL'DS IN PIPING SUBASSEMBLIES The enclosed draft of this proposed IE Bullstin is transmitted for your review and com5ent.

Comments received by March 9,1982 will be considered in preparation of the final revision.

.JNdan, irector Divisi of Engineering and Qual y Assurance, IE

Enclosure:

As' stated cc:

w/ enclosure:

see page 2 CONTACT:

W. J. Collins, IE 49-27275 8207130557 820310

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PDR REVGP NRCCRGR PDR O

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MAR 4 1982

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cc:

w/ enclosure D. G. Eisenhut, NRR

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R. H. Vollmer, NRR R. J. Mattson, NRR S. H. Hanauer,.NRR J. J. Kramer, NRR G. C. Lainas, NRR R. L. Tedesco, NRR M. Singh, IE 4

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SSINS No.:

6820 Accession No.:

820204010 IEB 82-(.L.

UNITED STATES NUCLEAR REGULATORY COMMISSION 0FFICE OF INSPECTION AND ENFORCEMENT WASHINGTON, D.C.

20555 March

', 1982

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Draft IE Bulletin:

ALTERATION OF RADIOGRAPHS OF WELDS IN PIPING SUBASSEMBLIES Description of Circumstances:

- On October 19, 1981 Washington Public Power Supply System (WPPSS) notified 'the NRC of finding aTterations to certain radiographs of 21' shop welds in piping

'subasse blies supplied to their WNP-Unit 3 by Associated Piping and Engineering m

C'orporation (AP&E) of Compton, California.

Further examination of essentially all AP&E radiographs previously sent to the site identified alterations on 14

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additional radiographs associated with eight welds in Class 1 stainless steel piping 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.

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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 O

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Draft IE Bulletin March

, 1982 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 j

are very difficult to detect by normal film interpretation techniques (i.e.,

subduedbackgroundlighting).

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.

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 the following:

1.

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

2.

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

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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IE Draft Bulletin March

,1982 Page 3 of 4.

Radiograph sets retained in AP&E file for WPPSS ' Unit 2 coni:ained unaltered radiographs which did not exhibit the code required 2-4T penetrameter sensitivity.

5.

That a number,of nuclear plant sites have received fabricated piping assemblies from AP&E which may have similar discrepancies as mentioned above.

The affected sites are listed in Table I.

ASME Section III Code Rules, Articles NB-5000 and NC-5000, requires weld quality acceptance of Class 1 and 2 piping be evaluated on the bases of radiography.

In radiography examination', meaningful interpretation of weld quality is dependent on utilization of a radiographic technique of sufficient sensitivity' as measured by the penetrameter image indicators.

The adequacy'of technique sensitivity is confirmed by the ability to visibly discern the appropriate T-hole images of the penetrameter when evaluating the radiographs for weld quality in accordance with the governing code rules.

Radiographs which have had penetfameter image quality indicators artificially enhanced by such methods discussed above violate ASME Code requirements.

Accordingl'y, the following actions are necessary to independently reverify -that the examined welds of these particular shop fabricated subassemblies a~e r

acceptable for plant service.

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Draft IE Bulletin March

,1982

.Page 4 of ActiontobeTakenbyAppiicantsofNear-TermOperatingLicensees(Group 1 Table-1):

1.

Determine on the bases of a 1007, revies of radiograph sets representing t

the shop fabricated subassemblies provided by AP&E, whether the applicable ASME Code penetrameter sensitivity (2-2T, or 2-4T as' required) is unaltered, i

clearly discernible and that code acceptable weld quality is demonstrated.

2.

In those cases where the specified penetrameter sensitivity is not discernible or is apparently enhanced in any manner, such as discussed above, weld quality interpretation may be based on the equivalent or higher penetrameter sensitivity discernible on the film sets.

To illustrate, for those radiograph sets for which the required 2-4T penetrameter sensitivity is no't discernible, or found artificially enhance'd upon visual inspection,'

film interpretation of weld quality may be based on the presence of discernible 2-2T, or 2-1T sensitivity exhibited by the radiographs.

3.

Where conformance to Item'1 and 2 cannot be satisfied, appropriate steps shall be taken to ascertain the acceptability of the affected welds by radiography reexamination and evaluation in accordance with the j

applicable ASME Section III Code requirements in effect for plant f

construction.

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4.

The above actions is to be completed within 30 days of rechipt of this bulletin.

All quality assurance records reflecting the actions taken, findings and disposition of discrep,ancies identified shall be maintained

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and available for NRC rev'iew.

5.

A written report which describes the findings and remedial actions (Items 1-4) taken, signed under oath $r affirmation under provisions of Section l

182a, Atomic Energy Act of 1954, shall be submitted within 45 days to the Regional Administrator of the appropriate NRC Regional Office.

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

20555.

Actions to.be Taken by Holders of Active Construction Permits or Constructi6n Permits Pending (Group 2; Table 1):

1.

The actions and reporting requirements of items 1 through 5 above shall be completed within 90 days of the issuance date of this bulletin.

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1 Draft IE Bulletin March

,1982 Page 6 of Actions to be Taken by Holders of Inactive or Cancelled Construction Permits or Construction Permit Applications (Group 3; Table-1):

1.

For information only.

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However, in the event of trar.:fer, sale or other consignment of the subject piping subassemblies to another nuclear plant site is contemplated, both the NRC and recipient permit holder, or licensee, is to be notified of the disposition of said subassemblies under provisions of 10 CFR 50 Part 21 regulations.

l This request for information was approved by GA0 under a blanket clearance number R0072 which expires November 50,1983.

Comments on burden and dupli-cation should be directed to the Office of Management and Budget, Room 3201,

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New Executive Office Building, Washington, D.C.

20503

Attachment:

1.

Table 1 G

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Draft IE Bulletin March 1982 TABLE 1 GROUP 1 GROUP 2 GROUP'3 l

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Grand Gulf, Units 1&2 Nine Mile Point 2 Bailly Unit 1 LaSalle, Units 1&2

' Hope Creek Units 1&2 Black Fox Units 1&2 River Bend Units 1&2 Hartsville Clinton, Units 1&2 Phipps Bend Shoreham Allens" Creek, Unit 1 Limerick, Unit's 1&2

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WPPSS-2 Group 1 - Indicates application for operating license has been docketed for review by Commission (NTOLs).

6 Group 2 - Active Construction Permits.or Construction Permits pending.

Group 3'- Inactive Construction Permits or Construction Permit applications

. cancelled or withdrawn.

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