ML20058C759

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Responds to Revision 1 to IE Bulletin 82-01, Alteration of Radiographs of Welds in Piping Subassemblies. No Evidence of Any Attempt to Artificially Enhance Pentrameter Image Sensitivity Exists
ML20058C759
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 07/16/1982
From: Wells D
DETROIT EDISON CO.
To: James Keppler
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
CON-NRC, REF-SSINS-6820 EF2-58493, IEB-82-01, IEB-82-1, NUDOCS 8207260440
Download: ML20058C759 (6)


Text

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Donald A. Wells Manager 0,aMy Ansvrere Of 3) ' 11 M7 t

2000 Second Avenue 31 3

July 16, 1982 EF2-58493 Mr. James G. Keppler Director Region III U. S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137

Dear Mr. Keppler:

Re ference. Enrico Fermi Power Plant, Unit 2 USNRC Licensing Docket 50-341 USNRC IE Bulletin 82-01, Revision 1 (5-7-82)

Subject:

Detroit Edison Response to NRC IE Bulletin 82-01 (Revision 1)

The enclosed Detroit Edison internal report number EF2-58493 is herein transmitted to you in response to IE Bulletin 82-01, Revision 1, " Alteration of Radiographs of Welds in Piping Subassemblies." The conclusion of this report is that there is no evidence of any attempt to artificially enhance the penetrameter image sensitivity.

This letter constitutes the Company's final report on IE Bulletin 82-01.

Should you require additional information from Detroit Edison in this matter, please advise us.

Very truly yours, h"(e l

J a

DAW /JDR/Im Enclosure 8207260440 820716 rM-21 1982 PDR ADOCK 05000341 G

PDR

4 Mr. James G. Keppler July 16, 1982 Page 2 EF2-58493 cc: Director Division of Reactor Construction Inspection Office of Inspection and Enforcement U. S. Nucicar Regulatory Commission Washington, D.C.

20555 Mr. Bruce Little, Resident Inspector U. S. Nuclear Regulaotry Commission Resident Inspector's Office 6450 North Dixie Highway Newport, Michigan 48166 Mr. L. L. Kintner Division of Project Management Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D.C.

20555

EF2-58493 4

Detroit Edison l

DETROIT EDISON RESPONSE TO IE BULLETIN 82-01 (REVISION 1)

ALTERATION OF RADIOGRAPHS OF WELDS IN PIPING SUBASSEMBLIES ENRICO FERMI ATOMIC POWER PLANT, UNIT 2 DOCKET NO.

50-341 JULY 1982

EF2-58493 IE BULLETIN 82-01, REVISION 1:

Alteration of Radiographs of Welds in Piping Subassemblies This Bulletin requested that the possibility of alterations to specific radiographs of piping welds by artificial enhancement of the ASME Code specified penetrameter image, at the Enrico Fermi Atomic Power Plant, Unit 2 (Fermi 2) site be investigated. This response discusses the questions directed to Holders of Construction Permits.

m m.

O EF2-58493 HOLDERS OF CONSTRUCTION PERMITS Action To Be Taken by Applicants for an Operating License and Holders of Active Construction Permits (Group 1, Table 1):

Determine on the basis of a 100 percent review of radiograph sets representing the welds associated with pipe wall thickness less R1 than %-inch in shop fabricated quality Class 1 & 2 subassemblies R1 provided by Associated Piping and Engineering Corporation (AP6E) of Compton, California, whether the applicable ASME Code penetrameter sensitivity (2-2T or 2-4T as required) is unaltered, and clearly discernible, and that acceptable weld quality is demonstrated.

BACKGROUND INFORMATION ASME Section III Code Rules, Articles NB-5000 and NC-5000, requires that o

.eeld quality acceptance of Class 1 and 2 piping be evaluated on the basis of radiography.

In radiography examination, meaningful interpretation of weld quality is dependent on the use of a radiographic technique of sufficient sensitivity as shown by the penetrameter image indicators on the film. 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 that have had penetrameter image quality indicators artificially enhanced violate the intent of ASME Code requirements, Associated Piping and Engineering performed the modification to o

the 12" risers on the Recirculation System. This modification consisted of two (2) tasks. Task 1 involved cutting the long leg from the elbow, inverting it, and rewelding. Task 2 involved machining the spool piece ends in preparation for the application of corrosion-resistant weld overlay, annealing the spool pieces, and application of weld overlay.

RESPONSE

Project Quality Assurance (PQA) has reviewed the Radiographs of all welded pipe assemblies supplied by Associated Piping and Engineering to the Fermi II Project. PQA has found the weld quality to be acceptable, the Radiographs to be in compliance with the 1971 ASME Section III (Winter 1971 Addenda, NB-5320), and no evidence of any attempted alteration to artificially enhance the penetrameter image sensitivity.

All radiographs were examined by the reflection technique using overhead lighting in order to reveal any alterations to the surface of the film.

There was no indication of tampering.

j

EF2-58493 Reference to the receiving records files, organized by supplier names, assured that all piping received from AP&E was accounted for. All i

welds on the spool P eces listed below were examined:

RD-2-A4 RD-1-B4 RD-2-A5 RD-2-B4 RD-2-A6 RD-2-B5 RD-2-A7 RD-2-B6 RD-2-AC RD-2-B7 RD-2-BB Most of the welds were for heavy wall pipe of various thicknesses.

In general, there was very good image contrast. There were very few welds of h" material in these shipments. Thus, the usual problems associated with interpretation of thinner wall dimensions were not a factor.

All quality assurance records reflecting these review findings will be maintained on site and will be available for NRC review.

Included in these records is Quality Surveillance Report #82235 dated 18 May, 1982.

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