ML20064F367
| ML20064F367 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 11/19/1982 |
| From: | Pollock M LONG ISLAND LIGHTING CO. |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20064F348 | List: |
| References | |
| SNRC-798, NUDOCS 8301060320 | |
| Download: ML20064F367 (4) | |
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.____.___..-_.3 175 EAST OLD COUNTRY ROAD + H IC K S VI L LE, NEW YORK 11001 MILLARD S. POLLOCM v,cr m mem-suctua SNRC-798 November 19, 1982 Mr. Thomas T.
Martin, Director Division of Engineering & Technical Programs U.S.
Nuclear Regulatory Commission, Region I King of Prussia, PA 19406 NRC Inspection No. 82-19 Shoreham Nuclear Power Station-Unit 1 Docket No. 50-322
Dear Mr. Martin:
This letter responds to your letter of October 15, 1982 which forwarded the report of the special inspection conducted by Mr. Richard H.
Harris of your office on August 2-13, 1982.
Your letter stated that it appeared that one of our activities was not conducted in full compliance with NRC requirements.
Apparent Noncompliance with 10CFR50. 55a (d) 10CFR50.55a(d) Piping, requires that for Construction Permits issued after January 1, 19 71, but be fore July 1,
- 1974, the reactor coolant pressure boundary piping must meet Class I requirements set forth in USAS B31. 7.
Nuclear Power Piping ANSI B31.7, paragraph B-1-120. 2 (c),
requires at least one penetrameter for each exposure and paragraph B-1-120.1 requires surface irregularities on both ID and OD be removed to a degree that resulting radiographh: contrast cannot mask or be confused with the image or an objectionable defect.
Contrary to the above, on August 4, 1982, Associated Piping
& Engineering Corporation radiographs were reviewed and found not to meet USAS B31.7 in that:
(1) Weld radiograph 1B21SH34-1-05, PS-1-A5, weld "B",
views 15-20 and 25-0 did not have one penetrameter for each exposure.
(2) Weld radiograph APE 14398 61871 Elll3WD25Dl, film area 3-4 had indication of surface irregularities on the OD that could mask or be confused with objectionable defects.
The indications of surface irregularities were not identified nor dispositioned.
8301060320 830104 PDR ADOCK 05000322 G
LONO ISLAND LIGHTING COMPANY Mr. Thoman T. Martin November 19, 1982 Page Two Comments 1.
AP&E's practice was to expose the radiographs of a circum-ferential weld and then process all film to be certain they were of acceptable quality prior to dismantling the panoramic exposure equipment set-up.
The radiographer, however, failed to relocate the penetrameter when a reshot was pe rformed.
All other exposure parameters remained unchanged; this was verified by density comparisons and weld image comparisons between film shot under these circumstances.
AP&E supplied 129 radiographed component welds each with approximately six views for a total of 774 individual views.
A LILCO review of all AP&E radiographs revealed that in addition to the two views described in Inspection Report 82-19, two other radiographs, one each on PSI-1-B1 Weld B and PS-1-Cl Weld A, the radiographs had no penetrameter images and no signs of film overlap.
The four views collectively identified by the NRC and LILCO represented 05 percent of the AP&E radiographic views supplied.
2.
As a result of NRC IE Bulletin 82-01, LILCO reviewed all AP&E radiographs for possible mechanical enhancement of penetrameter images.
During this review, it was noted that certain radiographs exhibited indications of OD surface irregularities.
It was determined at that time that these indications in no way interfered with the ability to properly interpret the radiographs.
It should be noted that the level of interpretation documentation required by the various enforcement agencies has changed over the years to include additional notation of acceptable and nonrelevant indications which may not have been required when these interpretation sheets were completed and reviewed by the Quality Organiza-tions.
Both LILCO and Stone & Webster are cognizant of the requirenents to record these irregularities and have demonstrated this to the NRC satisfaction.
Corrective Action and Results 1.
LILCO reviewed all AP&E radiographs.
The four views identified collectively by the NRC and LILCO as lacking images of penetra-meters were reradiographed.
The weld areas we found to be acceptable.
2.
As stated in the NRC report, LILCO prepared overlays of some of the radiographs that contain typical indications.
The overlays verified that the linear indications are caused by visible acceptable O.D. weld ripples.
A report to that effect has been issued.
Steps Taken to Prevent Recurrence As discussed above, all AP&E radiographs have been reviewed and
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LONG ISLAND LaGHTING COMPANY Mr. Thomas T. Martin November 19,'1982 Page.Three those that caused concern were either reshot or overlays prepared.
No rejectable indications were detected during this effort.
No further action is required.
Date of Full Compliance Full compliance has been achieved as a result of the corrective actions performed.
Very truly yours, try..c 2 A J M.
S.
Pollock Vice President-Nuclear cc:
Mr.
J.
Higgins i
All Parties l
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STATE OF NEW YORK
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ss.:
COUNTY OF NASSAU
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MILLARD S. POLLOCK, being duly sworn, deposes and says that I am a Vice President of Long Island Lighting Company, the owner of the facility described in the caption above.
I have read the Notice of Violation dated October 15, 1982, and also the response thereto prepared under my direction dated November 19, 1982.
The facts set forth in said response are based upon reports and information provided to me by the employees, agents, and representatives of Long Island Lighting Company responsible for the activities described in said Notice of Violation and in said response.
I believe the facts set forth in said response are true.
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'MILLARD S. POLLOCK Sworn to before me this
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