Bulletin 82-01: Alteration of Radiographs of Welds in Piping Subassemblies

                                                 SSINS No.:  6820          
                                                 Accession No.:            
                                                 8202041110                
                                                 OMB No.: 3150-0084        
                                                 Expiration Date:  3/31/83 
                                                 IEB 82-01                 

                                UNITED STATES
                        NUCLEAR REGULATORY COMMISSION
                    OFFICE OF INSPECTION AND ENFORCEMENT
                           WASHINGTON, D.C. 20555
                                     
                               March 31, 1982 

IE BULLETIN NO. 82-01:   ALTERATION OF RADIOGRAPHS OF WELDS IN PIPING 
                         SUBASSEMBLIES 

Description of Circumstances: 

On October 19, 1981, the U.S. Nuclear Regulatory Commission (NRC) was 
notified by Washington Public Power Supply System (WPPSS) that alterations 
were found in certain radiographs of 21 shop welds in piping subassemblies 
supplied to their WPPSS-3 by Associated Piping and Engineering Corporation 
(AP&E) of Compton, California. Further examination of essentially all AP&E 
radiographs previously sent to the site revealed alterations on 14 
additional radiographs associated with eight welds in quality Class 1 
stainless steel piping of less than 1/2-inch wall thickness. All affected 29 
welds in the thinwall piping were reexamined radiographically in accordance 
with the ASME Code. No evidence of unacceptable weld quality was identified.

The alterations consisted of artificial enhancement of the ASME Code 
specified penetrameter 4T-Hole image. This was apparently accomplished in 
one of three ways: (1) touchup with a soft lead pencil, (2) scribed or 
scratched with a sharp object, or (3) indention with a sharp object.  These 
forms of enhancement are very difficult to detect by normal film 
interpretation, techniques (i.e., subdued background lighting). However, 
utilizing direct overhead lighting, the alterations may be detected by close 
inspection of the film surface reflections as the film is being manipulated 
by the observer at various oblique angles. 

After this finding, an investigation was made at AP&E by the NRC Region IV 
staff on December 7-11, 1981. 

The results of the investigation were reviewed at the Region IV headquarters
and determined to be potentially generic. On January 29, 1982, the specific 
plants potentially affected were identified by the regional office. The 
investigation and review established the following: 

1.   Radiographs were altered on occasion by one Level II interpretor over 
     a period of approximately eight years prior to the date of this 
     investigation. 

2.   The alterations were limited to the set of radiographs of welds 
     submitted for customer review and approval. 
.

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                                                             March 31, 1982 
                                                             Page 2 of 3   

3.   The alterations involved welds associated with pipe wall thickness of 
     less than 1/2-inch that used isotope radiography techniques and a 
     number 10 or 12 penetrameter. 

4.   Radiograph sets retained in AP&E file for WPPSS Unit 2 contained 
     unaltered radiographs that did not exhibit the Code-required 2-4T 
     penetrameter sensitivity. 

5.   A number of nuclear plant sites receiving fabricated piping assemblies 
     from AP&E may have similar discrepancies. The affected sites are listed
     in Table 1. 

ASME Section III Code Rules, Articles NB-5000 and NC-5000, requires 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 
artificially enhanced by the discussed methods violate the intent of ASME 
Code require-ments. Accordingly, the following actions are necessary to 
independently reverify that the examined welds of the subassemblies 
fabricated by AP&E are acceptable for plant service. 

Action To Be Taken by Applicants for an Operating License and Holders of 
Active Construction Permits (Group 1, Table 1): 

1.   Determine on the basis of a 100 percent review of radiograph sets 
     representing the shop fabricated quality Class 1&2 subassemblies 
     provided by AP&E, 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 2-1T 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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                                                           March 31, 1982  
                                                           Page 3 of 3     

4.   The above actions are to be completed prior to issuance of an OL or 
     within 90 days of receipt of this bulletin, whichever occurs first. All
     quality assurance records reflecting the review findings and 
     disposition 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 affirmation 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 2; Table 1): 

No action required except as noted in Item 2, below. 

1.   For information only. 

2.   In the event reactivation of construction or transfer, sale, or other 
     consignment of the subject piping subassemblies to another nuclear 
     plant site is contemplated, 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. 

Attachments: 
1.   Table 1  
2.   Previously Issued IE Bulletins
.

                                                            Attachment 1   
                                                            IEB 82-01      
                                                            March 31, 1982 

                                 TABLE 1 
                  SITES WITH PIPING ASSEMBLIES FROM AP&E 

          Group 1                                      Group 2 

     Grand Gulf Units 1&2                         Bailly Unit 1 
     LaSalle Units 1&2                            Black Fox Units 1&2 
     River Bend Units 1&2                         Hartsville A1, B1, A2 & B2
     Clinton Units 1&2                            Phipps Bend 1&2 
     Shoreham                                     Allens Creek Unit 1 
     Limerick Units 1&2  
     WPPSS-2 
     Nine Mile Point 2 
     Hope Creek Units 1&2