Bulletin 82-01, Revision 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
NUCLEAR REGULATORY COMMISSTON
OFFICE OF INSPECTION AND ENFORCEMENT
WASHINGTON, D.C. 20555
May 7, 1982
IE BULLETIN NO. 82-01 REVISION 1: ALTERATION OF RADIOGRAPHS OF WELDS IN
All nuclear power reactor facilities holding an operating license (OL) or a
construction permit (CP).
This bulletin was previously forwarded on March 31, 1982 for action to the
CP holders of the reactors listed in Table 1 and for information to all
other reactor CP holders and licensees. Table 1 has been revised to add
three nuclear power reactor facilities. No revision has been made to the
scope of actions already requested. The bulletin is sent to the CP holders
of these facilities for action before issuance of an OL or within 90 days of
receipt of this revised bulletin, whichever occurs first. The action date
for all other facilities listed in Table 1 is unchanged.
The purpose of this revision to IE Bulletin No. 82-01 is to change Table 1
to reflect further information provided by Associated Piping and Engineering
Corporation regarding facilities for which they supplied piping assemblies.
A minor revision has been made to clarify the extent of the actions
required. (See revision to action item 1 on page 2).
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 thin-wall 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.,
IEB 82-01, Rev. 1
May, 7, 1982
Page 2 of 4
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
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 interpreter over
a period of approximately eight years prior to the date of this
2. The alterations were limited to the set of radiographs of welds
submitted for customer review and approval.
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
5. A number of nuclear plant sites receiving fabricated piping assemblies
from AP&E may have similar discrepancies. The affected sites as amended
(R-1) 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 requirements. 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 Operatinq 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 welds associated with pipe wall thickness less than
1/2-inch in shop fabricated quality Class 1 & 2 subassemblies
IEB 82-01, Rev. 1
May 7, 1982
Page 3 of 4
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-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.
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.
IEB 82-01, Rev. 1
May 7, 1982
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The format of Bulletins, Circulars and Information Notices has been changed,
effective April 5, 1982, to facilitate a centralized distribution. A change
has also been made to eliminate a separate transmittal letter.
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
1. Table 1
2. Previously Issued IE Bulletins
CONTACT: W. J. Collins
IEB 82-01, Rev. 1
May 7, 1982
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
Nine Mile Point 2
Hope Creek Units 1&2
Enrico Fermi 2 WPPS-5
Susquehanna 1 & 2
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