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: 
.

                                                         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. 
.

                                                          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
.

                                                          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