ML20055D059
| ML20055D059 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 06/21/1990 |
| From: | Rathbun D NRC OFFICE OF GOVERNMENTAL & PUBLIC AFFAIRS (GPA) |
| To: | Udall M HOUSE OF REP., INTERIOR & INSULAR AFFAIRS |
| References | |
| CCS, NUDOCS 9007030158 | |
| Download: ML20055D059 (16) | |
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June 21, 1990-.
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The Honorable Morris K; Udall, Chairman Coussittee on Interior and Insular Affairs.
United States House of Representatives Washington, DC 20515-
Dear Mr. Chairman:
g Enclosed, at.the request of Dr. Henry Myers of your staff, are responses '
to his requests of May 22, May 29, and June 6, 1990, concerning Seabrook welds.
Sincerely, f
Dennis K. Rathbun, Director -
Congressional Affairs Office of Governmental and Public Affairs
Enclosures:
As Stated cc: The Honorable Don Young 1'
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.i ATTACHMENT L
RESPONSE TO OR. H. MYER'S REQUESTS OF MAY 22, 1990 l
Request I:
.(paraphrased) Please provide the initial process shtets (approximately 6 pages
-l per weld) for the following welds:
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l RC-40 ' a. F0102, F0103 :
l 51-202-04. F0210 :
SI-251-12 F1210 l SI-256-01 F0114 l
51-256-04 F0411 SI-256-05 F0501 ~
SI-258-02 F0208 ,
SI-259-02 F0214 *,
SI-259-04 F0418 SI-272-02 F0215 SI-272-06 F0602 SI-272-06 F0613 SI-280-01 F0123
Response
The requested records for the three reactor coolant (RC) system field welds listed above were previously sent to the NRC EDO office for delivery to Con-
.gressional representatives in response to Senator Kennedy's letter of March 12, 1990. Specifically, the initial process sheets were part of the weld packages
.provided relative to Senator Kennedy's request for the weld records identified in his letter.
' With regard to the remaining safety injection (SI) system field welds listed above. the initial process sheets were express-mailed to the NRC EDO office in response to Request IV of Dr. Myers' memorandum of May 2, 1990. At that time weld packages for all of tha above SI field welds were provided except for SI-256-01, F0114, which is not a valid weld number. In its place the weld records for field weld SI-256-01, F0114 were sent since this weld number cor-responded with the Weld Repair Order listed by Dr. Myers in his request of May ,
2, 1990.
For all of the above field welds, the number of operational steps listed on the initial process sheets (and therefore the number of requested pages per weld) is dependent upon the size of the pipe, the complexity cf the welding process.
- and the ASME code requirements. Additionally, the initial process sheets may refer to other process sheets for the conduct of weld repairs. Thus, the weld packages previously sent for delivery to Dr. Myers contain other documents in addition to the initial process sheets.
Attachment 2 Request II:
We have received an allegation that deficiencies exist with regard to the -
radiographic record of cooling tower aiping welds. The allegation is that one or more welds in the main "T" to whic1 the spray headers are connected and/or one or more welds connecting the "T" to the spray headers were radiographed after the "T" was installed; the radiographs allegedly revealed significant veld deficiencies. The deficiencies at the "T" were repaired but, it is alleged, no further radiographs were taken. Please provide prior to COB, Wednesday, May 30 the Radiographic Inspection Reports for the cooling tower welds where the main "T" connects to the spray headers and for the six welds closest-to this connection.
Response
The requested Radiographic Inspection Reports are included in the complete record package for United Engineers & Constructors (UE&C) nonconformance report (NCR) No. 566. A microfilm copy of this NCR, which represents the best quality ..
copy which is readily available, was express-mailed to the NRC EDO office for delivery to Dr. Myers. It is noted that the only welds inspected by radio--
graphy in-the cooling tower spray header piping were specific welds identified in NCR No. 566 to have been made on two separate pipe spools (i.e., the "T" pieces themselves) supplied by the cooling tower vendor. Therefore, the re-quested Radiographic Inspection Reports for "the six welds closest to this connection" do not exist since radiography was not required by the governing code (i.e., ASME section III, subsection ND) in the examination and final acceptance of completed class 3 pipe welds. The selected, code acceptable method of nondestructive examination (NDE) for the subject welds was magnetic particle testing (MT). In other words, the radiography conducted on the "T" pieces was the only radiography conducted and it was only conducted as required by the disposition to NCR No. 566 which has been provided.
With regard to the allegation itself NRC inspection has determined that while the facts surrounding this allegation appear to be based in fact, the allega-tion itself is not substantiated. This conclusion was reached based upon the determination that the final disposition to UE&C NCR No. 566, and the related Pullman-Higgins NCR No. 2630 (also included in the NCR No. 566 package), re-quired removal of the welds in question and their replacement with new field welds. The final as-welded surface of these new welds was nondestructively examined by the MT method, as specified by the ASME Code, section III for class 3 weld joint acceptance and as was consistent with the original NDE technique implemented by the vendor for the supplied piping. Thus, the "T" spool welds containing the defects identified in NCR No. 566 were not " repaired", as is alleged, but rather were " replaced" under the controls of the ASME Code govern-ing such rework.
The differentiation between a " repair" vs. a " replacement" activity is central to the question of which of the governing ASME Code provisions must be followed. If the defects identified by radiography of the subject welds were
Attachment 3 to be eliminated by weld " repair", as was the intent of the earlier dis >osi-tions to NCR Nos. 566 and 2630, then subsequent radiography would have >een required to provide final acceptance of the completed weld. However, as is .
documented in a formal ASME Code Inter)retation, 111-1-86-68 (a copy of which i is attached), it was permissible, in t1is case, to perform MT examination of a I replacement weld, in lieu of repairing the original weld where the defects were detected by radiography. Similarly for the base metal repairs (BMR) documented in the NCR's, ASME section III, Article ND-4000 for the elimination and repair of defects specifies that radiography is not required if acccptable MT or liquid 1
-penetrant testing (PT) is performed. Therefore, although it is true that no J further radiographs were taken of the welds in question, radiography of these welds was not required by the ASME code.
The fact that the ASME Code allows the acceptance of final NDE by surface examination techniques (e.g., MT) is not unique to the cooling tower welds that -
are the subject of this allegation. Other welds of class 3 design installed et Seabrook Station, as well as other nuclear power plants, are typically final inspected and accepted by surface examinations. The ASME Code, section III, ,
generically requires final acceptable radiography of class 1 and 2 piping weld joints, but specifies that radiography is not required for class 3 weld joints.
Instead, the code requires that the design of class 3 weld joints account for a reduced joint efficiency for welds that are not fully radiographed. These pro-visions are discussed in the ASME section III, ND-3000 article specifying the requirements for the piping design of welds. Thus, class 3 component design, to include pipe welds, recognizes the reduced system operating requirements compared to class 1 or 2 component designs and compensates for the lack of a volumetric examination of the weld joints by applying efficiency factors to the
- weld joint design. In effect, the code allowance to conduct an MT or PT exami-nation on the final weld, instead of radiography, is recognition that the system design has accounted for the possibility of the existence of weld de-fects that would be otherwise unacceptable by radiograptic acceptance standards.
Therefore, when radiography was conducted on the subject cooling tower "T" .
spool pieces that had previously only been subjected to vendor MT, it was not surprising that defects were identified. UE&C NCR No. 566 and the supporting Pullman-Higgins NCR No. 2630 address these defects. NRC inspection has con-firmed, for the records reviewed, that both the base metal repair and the weld replacement activities were conducted as required by the final approved disposition to the NCRs ar,c in accordance with the ASME Code,Section III (1977 edition with winter '77 addenda). This review is still ongoing; we are waiting for the licensee to provide additional MT records. Should the additional HT records fail to confirm that all such welds were acceptably dispositioned. we will specifically inform you. While the NRC inspection of the weld records related to this issue is continuing, the allegation review is essentially complete. It has been determined that while certain details of the allegation have basis in fact, the allegation "that deficiencies exist with regard to the radiographic record of cooling tower niping welds" has not been substantiated.
. .'.lill14647,111.1 8644,11114649 Section lil, Divisions I cnd 2 - Interpretations NL 20 Interpretation: lil-146-67 J
Subject:
Section 111, Division 1, NS-4424 Surfaces of Welds; NB 5320 Radiographic Acceptance Standards (1983 Edition With Winter 1985 Addenda)
Date issued: September 30,1986 File: N186-071 Question: When a change of fitro density is identified as weld root concavity in a circumferential weld joint, does NB 5320(c) applyi Reply: No.
Interpretation: 111 1-86-68
Subject:
Section lil, Division 1, ND-5220 Examination of Class 3 Piping (1971 Edition With Summer 1973 Addenda)
Date issued: September 30,1986 File: N186 029 '
- Question: Is it permissible for Class 3 piping greater than NPS 4 to perform a magnetic particle or liquid penetrant examination in lieu of a radiographic examination if (a) the original weld was examined by radiography and defects were detected necessitating the repair, and (b) in lieu of repair, the deposited weld metal is completely removed and a new weld is madet Reply: Yes.
Interpretation: lll-146-69 l
Subject:
Section 111, Division 1, NF 3200 Design of Class 1 Component Supports, Appendix XVil (1974 Edition)
Date issued: September 30,1986 File: N186-039
. Question: Is it permissible for Subsection NF, Class 1, 2, and'3 applications to use NF.
3322.1(d)(3) (Appendix XVil, XVil-2214.3,1974 Code) for determining the allowable bending (plus i
merrbrane) stress on base plates which support only linear elements and component standard supportsi Reply: Yes, provided the base plate has been designated as an NF item. If the base ofate is i embedded and defined as building structure, the rules of NF do not apply to its design. l l l l
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- O ATTACHMENT RESPONSE TO DR. H. MYERS' REQUESTS OF MAY 29 AND JUNE 6, 1990 Request 1 (May 29, 1990)
Please provide prior to COB, Friday, June 1 the proc k ces that, prior to im-piementation of Procedure #5 in May 1984, governed the YAEC 100% radiograph ,
review. T*Is request encompasses procedures that mandated the review. It also encompasses procedures that ssecified and controlled the methodology of the review, the manner in which t1e review of saecific film packages would be re-corded and reported, and the manner in whic1 deficiencies would be handled.
Response
Prior to May 1984, no procedural requirement mandated YAEC 100% review of safety-related radiographs. Such reviews were conducted as surveillances governed by a YAEC Field Surveillance Procedure. Surveillances are not nor-mally intended to be 100% review or inspection efforts. However, with respect to Pullman-Higgins field weld film packages, the surveillance effort encom-passed a 100% radiograph-review as the film was turned over for YAEC record vault storage. Although the surveillance 7eports documenting such film review activities were not required to list each weld, evidence of the YAEC review of Pullman-Higgins, reviewer signature code-required or initials on radiographs has always the Radiographic been Reports Inspection provided RIRs).
by(YAEC That began when the first film packages were turned over by Pullman-HIggins to YAEC in 1979. Therefore, while the requirement for a 100% YAEC radiogra)h re-view was not proceduralized until May 1984, the final RIR~ record for eac1 weld should provide evidence of the review by YAEC. NRC inspection has not identi-fied any welds for which YAEC radiographic review was not conducted.
Prior to the implementation of the YAEC "QEG NDE Review Group" Procedure No. 5 in May 1984, YAEC radiographic review activities were governed by YAEC Field Surveillance Procedure No. 3. A copy of Revision 7 to this procedure (the re-vfrion in effect at the time the YAEC Field QA Manual was updated in April 1984, when the QEG NDE Review Group Procedure No. 5 was written) was express-mailed to the NRC EDO office for delivery to Dr. Myers. Included with the procedure were some YAEC Field QA Group Surveillance Reports, intended to sern as examples of the way the radiography review was conducted and documented. With regard to th' bove question concerning the methodology and manner of review, it should u ivted that a Master Checklist, arovided with each surveillance report, 1
ntablished the criteria used by t1e YAEC QA personnel performing the survell-
. Je. 'The parenthetical re'erences (e.g. T-270, SE-94) documented with tne Master Checklist criteria refer to the applicable paragraphs or sections of the ASME Boiler and Pressure Vessel Code,Section V, as they relate to radiographic requirements and standards.
l YAEC Field Surveillance Procedure No. 3 governed surveillance activities of the YAEC Field QA Group during Seabrook construction. That procedure specified general programmatic and documentation requirements, while the appropriate f
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e a Attachment 2 Master Checklist provided the specific technical inspection details. With re-gard to the question of how deficiencies were handled. Procedure No. 3 indi-cates in paragraph 3.1.4.5 that deficiencies could be either corrected immedi-ately, or transferred to the contractor's QA/QC program (e.g., a contractor nonconformance report could be written), or documented on a YAEC Deficiency Report (the handling and disposition of which are also discussed in Procedure ;
No. 3).
Attached to this response is an inspection report (IR) excerpt documenting the conduct of an NRC surveillance program inspection in the September-October 1983 time frarie. Procedure No. 3 was included in the NRC review of surveillance program requirements, as were samples of surveillance and deficiency reports.
An additional procedure (No. 4) referenced in this NRC inspection report excerpt, pertaining to the Field QA Checklists used in the conduct of surveillances, was also sent to the NRC EDO office for delivery to Dr. Myers.
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.. .' ATTPcH mE NT To REs PoHss .1 a .
SRC REstoH T .TMPECT\oN -
R EPORT 50- 443/ 6 3- % *arayafh F _
( rn. soc.w con.tute in 4h6u- ocue, Mea)
- 5. F_ield Quality Assurance $urveillane_e Program (Units J a'nd_2)
The inspector reviewed the YAEC Construction Field Quality Assurance-(CFQA)'
Manual procedures as follows:
(- -- Procedure No.1 Revision 4. dated 9/6/83, " Charter Of The Construction Field Quality Issurance Groups".
-- Procedure No.2, Revision $. dated 9/6/83 " Qualification Of Construction I 4
Field Quality Assurance Personnel". 1
-- Procedure No.3, Revision 7, dated 9/16/83, " Construction Field Surveillance Procedure". .
-- Procedure No.4, Revision 5, dated 9/16/83, " Construction Field Quality Assurance Check Lists". '
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- . Procedure No.5, Revision 4, dated 9/6/83, " Quality Assurance Records". ' '
dated 9
, -- Procedure No.6Training Quality Assurance Revision 2 Program"/6/83, "YAEC Construction Fie o
Additional procedure and instructions were reviewed, as follows:
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-- YAEC QA Procedure Q-113,' Revision 0, dated 3/26/80, " Deficiency Coding System". ,
-- Instruction " Surveillance Section Responsibilities".
In order to verify compliance with the above listed t
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the inspector reviewed one hundred and fifteen (115)surveillance proceduresreports and instructions, that had taken place from June thru September 1983 (Files numbered
' Q2.6.3 and Q2.6.14). The surveillance reports appeared to be thorough and timely for the field work that was in progress.
The inspector further reviewed the six (6) Deficiency Reports that resulted !
from the surveillance reports.
The actions taken to resolve the deficiencies {
' appeared to be adequate and timd y, and were reviewed for reportability per the requirements of 10CFR50.,55(e). 1 The inspector evaluated the surveillance program, particularly with regard i to Criteria XVI, XVII, and XVIII of 10CFR50, Appendix 8 and considers both the program and its implementation to be adequate, l No violations were identified.
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Attachnent 3 Request 2 (May 29, 1990):
If.the YAEC 100% radiograph review was not governed by procedures requested-in the foregoing item, please provide prior to COB, Friday, June 1 any documents other than procedures which mandated the review and/or describe the methodology of the review, the manner in which-the review of specific film packages was
- recorded _and reported, and the manner in which deficiencies were handled.
Response
See the response to Request 1.
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': Attachment 4 Request 3a & b (May 29, 1990):
(paraphrased) Please provide:
- a. A listing of the welds associated with the radiograph discrepancies enumerated in YAEC Deficiency Reports 527 and 574.
- b. A listing of the several hundred welds reradiog-aphed after radiographs were rejected by YAEC in the course of its review of radiographs approved by Pullman-Higgins. [At the May 25 meeting, the number of such radiographs was at one point estimated to be in the neighborhood of 400.]
Response
Neither of the requested lists is readily available. While a weld-by-weld searih of the radiographic film package documents would provide some of the requested information, such a task is impractical. Even after an intensive search, the results would be incomplete.
As is discussed in the response to Request 1 the final acceptability of a radiograph and of the weld it represents was verified by YAEC reviewer signa- )
ture or initials on the Radiographic Inspection Report (RIR) for safety-related welds. Thus, the deficiencies identified in the subject deficiency reports l l
(DRs) did not have to be correlated (in the DRs themselves) with the welds to l which they applied, because an unacceptable radiograph would not have had its associated RIR signed'off by YAEC. Interviews with YAEC QA personnel involved in the NDE Review Group activities revealed that a decision was made not to l correlate.each deficiency with the affected weld so that YAEC could elicit peneric corrective action from Pullman-Higgins rather than provide a detailed ist of items to be corrected.
With regard to the reradiography required by the YAEC film review process, the aforementioned weld-by-weld record search would identify a number of the welds (
s requested. However, such a list would not necessarily be complete since only final acceptable RIRs evidencing complete weld coverage and final weld quality were required to be retained as quality records. Therefore, RIRs accepted by Pullman-Higgins, but not signed as accepted by YAEC (i.e., the situation for which Dr. Myers is requesting a listing of welds), did not require retention.
This-fact would relegate the compliation of any such list to a detailed examin-ation of the weld records. As indicated previously, such a search would be ,
l both resource intensive and inconclusive.
.The final quality of each safety-related weld is demonstrated by the available ,
l e quality records. The lack of listings of the type requested does not adversely affect the ability to make an adequate cetermination of weld quality.
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4 Attachment 5 Request 3c (May 29, 1990): ,
(paraphrased);Please provide:-
- c. A listing of the welds that were the subject of Mr. Wampler's 16 not-completed nonconformance reports.
Response
It is our understanding that this information will be addressed in the report of the NRC Independent Regulatory Review Team established to review welding at Seabrook Station.
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Attachment 6 Request 3d (May 29, 1990):
(paraphrased) Please provide:
- d. A listing of the dates on which the following welds were completed per Field Weld Process Sheet, Line 44: RC-3 F0102, RC-9 F0102, RC-10 F0101, RC-10 F0102.
Response
The initial Field Weld Process Sheets for the reactor coolant (RC) loop piping welds.noted above indicate in Step 44 the direction to the welders to " complete wold." Such welding can comence only after the holdpoint ("H") assigned to Step 43 regarding informational radiography is signed off as completed. Also, a holdpoint had been assigned to Step 45 involving the measurement of weld shrinkage. Thus, the dates on the process sheets associated with the hold-points assigned to Steps 43 and 45 would bracket the completion of welding and provide the time frame for weld completion requested by Dr. Myers, if no sub-sequent weld repairs were required.
In the case of each RC loop field weld noted in-the above request, repair weld-ing was required. The chronology of repairs for each of the subject welds is different. Certain welds were rejected, based upon the informational radi-ography of Step 43, and in-process repairs were initiated. Other welds rare rejected based upon the nondestructive examination (NDE) conducted in process sheet sters subsequent to Step 45, resulting in the initiation of a formal re-pair cycle. Also, for certain of the subject welds, subsequent NDE resulted in the identification of the need for base metal re) air. That led to the assign-ment of additional field weld numbers to track tiese repairs, which were con-e.idered separate from the original field weld.
Despite'the case-by-case uniqueness of repair of each of the questioned welds, all of the weld repairs required the issuance of new process sheets to provide direction to the welders and inspectors and to document the weld history record.
Therefore, by reviewing the weld lackage for each of the four requested RC loop welds, it is possible to establisi the time period when final welding was com-pleted. Similar to the initial process sheet, the time periods are bracketed by holdpoint dates.
At the time of construction completion, precise dates of welding completion for each weld could have been established by the Weld Rod Stores Requisitions docu-menting the issuance of welding filler metal for each weld. However, the Weld Rod Stores Requisition slips were not turned over by Pullman-Higgins to YAEC I as QA records because the requisite traceability of material wat provided by recording the filler metal heat numbers and electrode lot numbers on the Field Weld Process Sheet for each weld. ]
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t Attachment 7 Welding completion dates for each of the requested welds were determined from a review of the weld packages. These weld records have been previously provided to congressinnal representatives in response to Senator Kennedy's request of March 12, 1990.- Time frames for the completion of welding on each of requested-welds are indicated below:
Weld Welding Completed RC-3, F0102 September 20-21, 1983 RC-9, F0102 December 22-28, 1983 RC-10. F0101* July 14-16, 1981 RC-10, F0102 February 10-17, 1984
- NOTE: It should be recognized that NDE conducted subsequent to the completion of this field weld identified defects requirin As discussed above, separate field weld numbers (g base e.g., RC-10, F0105)metal repairs (BMRs).
were assigned to these repairs. Therefore, the dates listed above represent the time frame of completion of the original weld and not the separate base metal repairs con-ducted subsequently. Attached to this response is an inspection report (IR) excerpt documenting NRC inspection of Repair Weld (RC-10, F0105) activities during the July-August, 1983 time frame. Where BMR activities required welding, separate process sheets corresponding to the assigned BMR field weld number provided a record of completion of the base metal repair welding.
WThcH mEHT TO R ESPONW 34 WRC TEG tc>N y INJ;#ECTioN REPORT 50- 443/ B 3 'l 3 > p a yach F a.
I g'fut pec.kiO6 conduc.it d th N Y ~ b j4Jh $ 6
- 5. Re_a_ctor coolant Pressure Boundary (RCPB)_Insta_11ation (Unit _11
- 4. Repair Welding The inspector observed the in-process preheat and weld repair preparations for a base metal repair to an RPV nozzle safe end.
The excavated cavity was mapped to include the stainless steel safe
, end, the inconel weld attaching the safe end to the RPV P-3 carbon l steel material, and the field weld attaching the stainless steel .
pipe spool to the safe end. A post weld heat treatment (PWHT) of the I area after repair welding was accomplished to meet the intent of ASME Section III, Subsection N8-4643, by soaking the weld area for l two hours at a temperature range of 400-500F.
The inspector reviewed the Repair Weld (RC-10-01, F0105. Repair /1)
Process Sheet,'the Welding Procedure Specification (Pullman 655-!II-3/8-CL-2), the Weld Red Stores Requisition (ENi-Cr-Fe-3 electrode),
and thennocouple heat tracing charts for both the preheat and PWHT periods. Disposition for repair of this weld was provided by
- Pullman NCR 5026.
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The conduct of the repair operation was discussed with contractor, I A/E and licensee QA and welding engineers, particularly with regard i to the decision to waive the half-bead temper technique requirements and to the degree of involvement of Westinghouse and ANI personnel in the repair technique planning. The inspector verified Pullman -
QC mandatory hold point inspection and routine surveillance during the repair process.
Final radiographic examination and liquid penetrant examination of the repaired area are planned and the inspector has no questions regarding the conduct of the RP".' nozzle repair at this time.
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Attachment 8 Request 4 (May 29, 1990): ,
With regard to item 2-b, please inform me as to whether the welds listed in 4 i
Deviation Notice 090 constitute a portion of-the welds reradiographed as a re-sult of the YAEC review of radiographs approved by Pullman-Higgins. Were the radiographs listed in the attachment to DN-090 discarded and replaced by the new radiographs made pursuant to DN-090?
Response
-It is our understanding that this information will be addressed in the report of the NRC Independent Regulatory Review Team established to review welding at Seabrook Station.
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Attachment 9 Request 5 (only request of June 6, 1990): i (paraphrase'd) Please provide those Radiographic Inspection Reports (RIR's) i which were retained in weld packages for the following 25 Reactor Coolant (RC) 1 loop field welds: j i
RC-1: F0101, F0102 !
RC-2: F0101, F0102, F0103, F0104 i RC-4: F0102 !
RC-5: F0101, F0102, F0103, F0104 RC-6: F0101, F0102 RC-7 F0101 RC-8: F0101, F0102, F0103, F0104 RC-9: F0101 RC-11: F0101, F0102, F0103, F0104 RC-12: F0101, F0102 Response: ;
The RIRs retained as QA records with the radiographic film packages for all 25 of the RC loop field welds requested above were express-mailed to the NRC EDO office for delivery to Dr. Myers.
Along with the requested RIRs, a June 11, 1990 licensee memorandum regarding-RIR " Corrections" was provided. That memorandum was generated in response to some documentation errors, identified by the NRC during inspection of the weld-ing records. The errors related to RC loop piping diameter and wall thickness
-data. The NRC Independent Regulatory Review Team questioned this while con-ducting independent calculations of the geometric unsharpness (Ug) of the radiographs.*-
.On June 1, 1990, the NRC Senior Resident Inspector (SRI) for construction're-quested that the licensee review the records for the large-diameter RC loop ,
welds for similar errors, recalculate Ug numbers to ensure that code require- 1 ments had not been violated, and provide documented evidence of correction of the affected records. The licensee completed these tasks and the SRI reviewed i the new Ug calculations to confirm that the code criteria for the sharpness of' the radiographic images had been met. The correction to the RIR records was accomplished by attaching a copy of the " corrections" memorandum to each affected RIR.