ML20079P582
| ML20079P582 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 12/15/1983 |
| From: | Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20079P574 | List: |
| References | |
| NUDOCS 8401310272 | |
| Download: ML20079P582 (3) | |
Text
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PHILADELPHIA ELECTRIC COMPANY 23O1 M ARKET STREET P.O. BOX 8699 PHILADELPHIA. PA.19101 SHIELDS L DALTROFF
.EOU'5EEo December 15, 1983 Docket No. 50-277 Insoection No. 50-277/83-28 Mr. Thomas T. Martin Division of Engineering and Technical Programs U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406
Dear Mr. Martin:
Your letter of November 16, 1983, forwarded Inspection Report 50-277/83-28.
Aopendix A addresses one item which does not appear to be in futi compliance with Nuclear Regulatory Commission requirements.
This item is restated below along with our response.
10CFR50, Apnendix B, Criterion V, requires that activities affecting quality shall be prescribed by documented procedures and shall be accomplished in accordance with these procedures.
The Peach Bottom QA Program, paragraph 5.1, requires that activities affecting quality be accomolished in accordance with documented procedures.
Lambert-McGill-Thomas, Inc.
ultrasonic examination procedure number UT-38, Revision 0, paragraph VII.D.3, recuires that search units be selected according to Table 1.
Table 1 requires that the straight beam search unit shall not exceed 0.5 inches diameter for the examination of weld overlay material.
Contrary to the above, during the oeriod from August 22, 1983, to September 30, 1983, weld overlay material on welds 2-AHJ-3, 2-BHC-3, 2-BHE-2, 10-0-5, 10-0-6 and 10-0-11 was examined ultrasonically using a 1-inch diameter search unit.
This is a Severity Level IV Violation (Supplement II).
8401310272 840125 PDR ADOCK 05000277 G
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Response
This occurrence resulted from a personnel error on the part of a contractor in selecting a transducer to be used in ultrasonic examination.
A Lambert-McGill-Thomas, Inc. (LMT)
Level III examiner authorized the use of a one (1) inch diameter transducer which meets code requirements and is technically sound.
The ultrasonic examination procedure, LMT, UT-38, Rev. O, required a search unit transducer with a maximum diameter of 0.5 inches.
The examiner had not been a party to the procedure development, but had read the procedure and apparently did not recognize the limitation of maximum diameter for the search unit.
Upon notification of this apparent violation by the NRC
-- inspector, a field change to the procedure was immediately initiated.
This change permitted the use of the larger transducer.
The revised procedure was aporoved for use by Philadelphia Electric Company and its use was instituted on October 7, 1983.
__ The LMT Level III examiner was counselled on the proper use and review of existing procedures.
Philadelphia Electric Company personnel responsible for OC review of the contractor data was also counselled with respect to the prooer use and i
review of existing orocedures.
Although the six weld examinations identified by the Inspector were apparently not performed in accordance with tha requirements of UT-38, Rev.
O, the cuality of the examination was not impaired.
The near field divergence of ultrasound can affect examination results; however, its effect in these examinations would not be significant.
The primary purpose of the straight beam examination used here is to detect a lack of bond between the overlav material and the base metal.
Successful repeatable calibrations obtained from reflectors located in the area of interest demonstrated the minimal affect of the near field on these examinations.
The test blocks used for these calibrations are representative of the weld thicknesses and pipe diameters which were examined.
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Hr.. Thomas T. Martin Pcga 3 Docket 50-277 ASME Section V, Article 5, Ultrasonic Examination, 1980 Edition, upon which this procedure is based, specifies the following for straight beam transducers for cladding examinations:
"T-554.1 Equipment.
Straight beam search units with a maximum transducer area of one square inch (625 sq.
mm) shall be used.
A nominal frequency of 2.25 MHz shall be used; however, other freauencies may be used to achieve the necessary resolution."
The transducer utilized by Lambert-McGill-Thomas, Inc.,
during weld examinations, meets the requirements of the code because the transducer area is slightly less than one square inch.
Should you require additional information, please do not j
hesitate to contact us.
Very truly yours, A, a 3-s j
cc:
A.
R. Blough, Site Inspector
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