ML20127A868

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Responds to 921125 Response to Notice of Nonconformance. Corrective Actions Determined to Be Adequate for All Nonconformances.Discussion on Practice for Determining When Welds Are Inaccessible Did Not Adequately Identify Controls
ML20127A868
Person / Time
Issue date: 01/06/1993
From: Norrholm L
Office of Nuclear Reactor Regulation
To: Gardner G
CONNEX PIPE SYSTEMS, INC.
References
REF-QA-99901255 NUDOCS 9301120096
Download: ML20127A868 (4)


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January 6, 1993 Docket No. 99901255 Mr. G. Gardner, Chief Executive Officer Connex Pipe Systems, Inc.

1115 Gilman Street Marietta, Ohio 45750

Dear Mr. Gardner:

SUBJECT:

EVALUATION AND CONCLUSIONS REGARDING THE REPLY TO THE NOTICE OF NONCONFORMANCE (NRC INSPECTION REPORT NO. 99901255/92-01)

I am responding to Connex Pipe Systems, Inc.'s (Connex's) November 25, 1992, reply to the Notice of Nonconformance which was issued by the-U.S. Nuclear Regulatory Commission (NRC) on November 4,1992, following an NRC inspection of Connex's facility in Marietta, Ohio.

Also, addressed is our review of Connex's discussion of its practice for determining when welds are inaccessible for nondestructive examination (NDE).

The Notice of Nonconformance identified activities which failed to comply with the requirements of Appendix B to Part 50 of Title 10 of the Code of Federal Regulations (10 CFR Part 50) and your Nuclear Quality Assurance Manual.

Your corrective actions were determined to be adequate for all Nonconformances.

However, your discussion on Connex's practice for determining when welds are inaccessible for NDE did not adequately identify controls for ensuring that required NDE is performed on accessible weld surfaces. 99 December 14, 1992, Mr. L. L. Campbell of this office discussed with Mr. K. A. Welch of Connex the need to incorporate additional requirements in Connex's work control process to ensure required NDE is performed. The accessibility of the internal weld surfaces of an 8 inch diameter x 6 inch long pipe welded to a 36 inch diameter pipe fabricated by Connex during the recent NRC inspection was riiscussed.

If this welding had been to ASME Class I requirements Connex's current practice would have resulted in the required NDE not being performed on the weld _'s internal surface even though this surface was accessible for NDE at st,me point during the fabrication process.

It was further discussed that Connex should-review its practice of performing NDE at -the final stage of the fabrication process and implement appropriate controls to ensure required NDE is performed.

We will review the implementation of your corrective actions and actions to.

prevent recurrence, as described in your reply to the Notice-of Nonconformance, during a future inspection to ensure that full compliance to 10 CFR Part 50'nas been achieved and will be maintained. At that time, we will also reassess the weld accessibility issue.

In accordance with Section 2.790 of 10 CFR, " Rules of Practice," a ccpy of this letter will be placed in the NRC's Public Document Room.

930'1120096 930106 PDR GA999.EMVCONPS 99901255 PDR f@ ?

Mr. G. Gardner If you have any questions concerning the inspection and this reply, we will be glad to discuss them with you.

Sincerely, f

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orr'holm, Chief Vendor Inspection Branch Division of Reactor inspection and Licensee Performance Office of Nuclear Reactor Regulation T

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Mr. G. Gardner January 6, 1993 DISTRIBUTION:

Central Files / Docket Files / RIDS IE:09 VIB R/F DRIL R/F

  • See previous concurrence 0FFICE VIB/DRIL VIB/DRIL VIB/,DRIL fs)

,NAME LCAMPBELL UPOTAPOVS Lii&}

M DATE 12/23/92

  • 12/23/92
  • 01/(o /93

'YES j NO

'YES)N0 (dO]

COPY OF DOC YES 0FFICIAL RECORD COPY ~

DOCUMEfITNAME: A:CONNEX.LTR

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I Mr. G. Gardner 3-January 6, 1993 DISTRIBUTION:

Central Files / Docket Files /RIOS IE:09 VIB R/F DRll R/F

  • See previous concurrence f0FFICE VIB/0RIL VIB/0RIL VIB/DRIL

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o NAME LCAMPBELL UP0TAPOVS Lthf 90M 4

l0 ATE 12/23/92

  • 12/23/92
  • 01/6/93 fl0 )

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{COPYOFDOC YES YES N0 0FFICI AL RECORE, COPY DOCUMENT NAME: A:CONNEX.LTR

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