Bulletin 82-01: Rev. 1, Supplement 1: Alteration of Radiographs of Welds in Piping Subassemblies
SSINS NO.: 6820
OMB No.: 3150-0084
Expiration Date: 3/31/83
IEB 82-01 Rev. 1
Supplement 1
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
WASHINGTON, D.C. 20555
August 18, 1982
IE BULLETIN NO. 82-01, Rev. 1, Supplement 1: ALTERATION OF RADIOGRAPHS OF
WELDS IN PIPING SUBASSEMBLIES
Addressees:
All nuclear power reactor facilities holding an operating license (OL) or
construction permit (CP).
Purpose:
The purpose of this supplement is to inform CP holders and licensees about
events with potentially significant impact upon the health and safety of the
public and to request appropriate action. IE Bulletin 82-01 Rev 1 notified
licensees and CP holders about alterations to radiographs supplied to
Washington Public Power Supply System (WPPSS) Unit 3 by Associated Piping
and Engineering Corporation of Compton, California. This present supplement
describes alterations of radiographs that ITT Grinnell Industrial Piping,
Inc. of Kernersville, North Carolina supplied for Consumer Power Company and
is forwarded for action to reactor CP holders and licensees listed in Table
1 and for information to all other reactor CP holders and licensees.
Description of Circumstances:
In November of 1981, Consumers Power Company (CPC) notified the U.S. Nuclear
Regulatory Commission (NRC) that alterations were found in four sets of
piping weld radiographs supplied to the Midland 1 plant by ITT Grinnell
Industrial Piping, Inc. of Kernersville, North Carolina. These alterations
were discovered during a review of approximately 94,000 shop radiographs.
The alterations consisted of artificial enhancement of the penetrameter
4T-hole image specified in the ASME Code. The radiographs appeared to have
been altered in one of three ways: (1) touching up with a soft lead pencil,
(2) scribing or scratching with a sharp object, or (3) indenting with a
sharp object. These forms of enhancement are very difficult to detect by
normal film interpretation techniques (i.e., subdued background lighting).
Using direct overhead lighting, the alterations may be detected by close
visual inspection of film surface reflections as the film is manipulated at
various oblique angles.
An investigation was performed at the ITT Grinnell facility on March 16-18,
1982. Region IV and IE reviewed the results of the investigation and
concluded that a potentially generic problem existed. The investigation and
review established the following:
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IEB 82-01, Rev. 1
Supplement 1
August 18, 1982
Page 2 of 3
1. Radiographs were altered on occasion over a period of approximately six
years prior to the date of this inspection.
2. Radiographs had been altered were for welds of pipes with wall
thicknesses less than 1/2-inch for which isotopic radiography and
number 7 or 10 penetrameters were used.
3. Certain weld radiographs, had been altered for piping subassemblies
that were furnished to TVA's Hartsville Units A1, A2, B1, and B2.
4. Similar discrepancies may exist at other nuclear plants (listed in
Table 1) using fabricated piping assemblies from ITT Grinnell,
Kernersville, NC.
ASME Section III Code Rules, Articles NB-5000 and NC-5000, require that weld
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
artifically enhanced by the discussed methods violate the intent of ASME
Code requirements. Accordingly, the following actions are necessary to
reverify independently that the examined welds of the subassemblies
fabricated by ITT Grinnell are acceptable for plant service.
Action To Be Taken by Licensees, Applicants for an Operating License, and
Holders of Active Construction Permits (Groups 1&2, Table 1):
1. Determine on the basis of a 100 percent review of radiograph sets
representing the welds associated with pipe wall thickness less than
1/2-inch in shop fabricated quality Class 1 & 2 subassemblies provided
by ITT Grinnell, Kernersville, NC, 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.
2. In those cases where the specified penetrameter sensitivity is not
discernible or, is apparently enhanced in any manner, as by the methods
discussed, weld quality interpretation may be based on the equivalent
or higher penetrameter sensitivity discernible on the film sets. For
example, for those radiograph sets for which the required 2-4T
penetrameter sensitivity is not discernible, or found artificially
enhanced on visual inspection, film interpretation of weld quality may
be based on the presence of discernible 2-2T or 2-lT sensitivity
exhibited by the radiographs.
3. Where conformance with Items 1 and 2 cannot be satisfied, appropriate
steps shall be taken to ensure the acceptability of the affected welds
in accordance with the applicable ASME Section III Code requirements in
effect for plant construction.
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IEB 82-01, Rev. 1
Supplement 1
August 18, 1982
Page 3 of 3
4. The above actions are to be completed within 90 days of receipt of this
bulletin for plants in Group 1, Table 1. For plants in Group 2, Table
1, completion is required within 90 days of receipt of this bulletin or
prior to issuance of an OL, whichever comes first. All quality
assurance records reflecting the review findings and dispositon of
discrepancies identified shall be maintained and available for NRC
review.
5. A written report describing the findings and corrective actions taken,
signed under oath or affimation under provisions of Section 182a,
Atomic Energy Act of 1954, shall be submitted within 30 days after
completion of Items 1 through 4 to the Regional Administrator of the
appropriate NRC Regional Office. A copy of the report is to be
forwarded to the Director, Office of Inspection and Enforcement, NRC,
Washington, D.C. 20555.
Actions To Be Taken by Applicants for Construction Permits or Utilities
Whose Construction Permits Are Suspended or Delayed (Group 3; Table 1):
No action required unless reactivation of construction or transfer, sale or
consignment of the subject piping subassemblies to another nuclear plant
site is contemplated. In such cases both the NRC and recipient permit
holder, or licensee, are to be notified of the disposition of said
subassemblies under provisions of 10 CFR Part 21 regulations.
This request for information was approved by OMB under clearance number:
3150-0084. Comments on burden and duplication should be directed to the
Office of Management and Budget, Reports Management, Room 3208, New
Executive Office Building, Washington, D.C. 20503.
If you need additional information, please contact the Regional
Administrator of the appropriate NRC Regional Office or this office.
Richard C. DeYoung, Director
Office of Inspection and Enforcement
Technical Contact: M. S. Wegner
301-492-4511
Attachments:
1. Table 1
2. List of Recently Issued IE Bulletins
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Attachment 1
IEB 82-01, Rev. 1
Supplement 1
August 18, 1982
TABLE 1
SITES WITH PIPING ASSEMBLIES FROM ITT GRINNELL
Group 1 Group 2 Group 3
Arkansas Nuclear One Nine Mile Point 2 Hartsville A1, B1, A2,& B2
Davis-Besse Marble Hill 1&2 Phipps Bend 1&2
Farley 1&2 Midland 1&2
McGuire 1&2 Comanche Peak 1&2
Susquehanna 1&2
Catawba 1&2
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