ML19274D916

Responds to NRC 781107 Ltr Re Violation Noted in IE Insp Rept 50-277/78-27.Corrective Actions:All Nondestructive Testings Contractors Performing Radiography Will Be Required to Submit Written Documentation

ML19274D916
Person / Time
Site:	Peach Bottom
Issue date:	11/28/1978
From:	Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Robert Carlson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML19274D901	List: ML19274D916
References
NUDOCS 7902270224
Download: ML19274D916 (2)

Text

PHILADELPHIA ELECTRIC COMPANY 2301 M A RK ET STR EET P.O. BOX 8699 PHILADELPHIA PA.19101 SHIELDS L. DALTROFF ELacta c Pn cTton November 28, 1978 Re: Docket No.: 50-277 Inspection No. 50-277/78-27 Mr. Robert T. Carlson, Chief Reactor Construction & Engineering Support Branch Office of Inspection & Enforcement US Nuclea r Regula tory Commission Region I 631 Park Avenue King of Prussia, PA 19406

Dear Mr. Carlson:

Your letter of November 7, 1978 forwarded Inspection Report 50-277/78-27. Appendix A to your letter addresses two items which did not appear to be in compliance with Nuclear Regulatory Commission requirements. Items A and B are infractions. As your letter indicates, Item B has been resolved and requires no further response. Item A is restated below with our response.

10 CFR 50, Appendix B, Criterion IX, states, in part, that:

" Measures shall be established to assure that special processes, including... nondestructive testing, are controlled and accomplished by qualified personnel using qualified procedures in accordance with applicable codes...and other special requirements."

Contrary to the above, on September 21, 1978, radiographs of Nuclear Class 1 pipe welds were being p rocessed withou t written procedures to assure quality of final radiographs.

Response

Philadelphia Electric Company requires any nondestructive testing con t ra c tor to supply his written nondestructive 790227 cagy

, ~',. *

1 r . Robert T. Carlson, Chief Page 2 testing procedures for review and approval p rior to that contractor performi.'g any nondestructive testing. In accordance with this reguirement, the contractor performing the radiography referet.ced in Item A above submitted his written radiographic p rocedu res which were reviewed and approved by Philadelphia Electric Company personnel on September 12, 1978.

The cont rac t o r 's radiographic procedure states in Section 3.1 entitled, " Film Processing", and Paragraph 3.1.1,

" Procedure for Processing", that:

"All film shall be processed in accordance with Part III of Recommended Practice SE-94."

Recommended Practice SE-94 is included as Article 22 of Section V of the ASME Boiler & Pressure Vessel Code and contains a p roce du re for the processing of radiographs which meets ASME Code and NRC requirements for quality.

A review of this~ contractor's quality ascurance procedures by Philadelphia Electric QA personnel, however, concluded that although the contractor had established written

. p ro ce du re s for the processing of radiographs to required quality levels, there was insufficient documentation provided to assure that radiographs were being processed in .

accordance with the required p rocedure. To remedy this situation, effective Novenber 20, 1978, all nondestructive testing contractors performing radiography will be required to submit written documentation of the variables utilized during film processing, thereby assuring that all radiographs are being processed i n a cco'. da nce with established procedures.

Should you require any further information on this subject, please do not hesitate to contact us.

Very truly yours,

/

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