ML20147E625

Provides Results of Review of Issues Re Deferral of ASME Code Hydrostatic Test of Loop 3 Cold Leg Pipe Subassembly Described in Insp Repts 50-445/85-07 & 50-446/85-05.Arlotto Rept Does Not Adequately Address Two Concerns on Issue

ML20147E625
Person / Time
Site:	Comanche Peak
Issue date:	08/31/1987
From:	Hunter D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20147E473	List: ML20147E468 ML20147E488 ML20147E515 ML20147E552 ML20147E592 ML20147E625 ML20147E648 ML20147E674
References
FOIA-87-677 NUDOCS 8803070112
Download: ML20147E625 (8)

See also: IR 05000445/1985007

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UNITED STATES

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NUCLEAR REGULATORY COMMISSION

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611 RYAN PLAZA DRIVE, SulTE 1000

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AUG 3 ! 587

MEMORANDUM FOR: _ Robert D. Martin, Regional Administrator

FROM: D. R. Hunter, Chief, Reactor Project Section 8

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SUBJECl:

ASME CODE HYDR 0 STATIC TEST OF RCS PIPE SUBASSEMBLIES

PURPOSE:

As a followup to our discussion on August 26, 1987, in your office. I

indicated that I did not fully understand certain conclusions stated in the

Arlotto Report. I indicated that I would perform a review of the issues

concerning the deferral of the ASME Code hydrostatic test of the loop 3 cold

leg pipe subassembly at CPSES. The Arlotto conclusions did not fully address-

the issue, as I understand the matter, from my close involvement at the time

of the Region IV inspection efforts (NRC IR 50-445 85-07; 50-446/85-05, draf t

and final reparts.) The conclusions made by the Arlotto report did not

support the thought process in 1985 when the inspection effort was perfonned.

I reviewed a number of reference documents in order to better understand the

Arlotto report h. conclusions regardino ime 5 that, "no direct safety

significance" and that after consi.aering "worst case" that "recommendations

are unnecessary."

BACKGROUND

As a matter of background, Region IV perfonned inspection of certain activities

at CPSES in June 1985 in order to better understand scope of the safety and

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quality issues. The compliance with the ASME Code had not been specifically

looked at during previous NRC/TRT activities. It was deemed to be extremely

important to review this area. Del Norman was selected to look at this

particular area. Based on the NRC inspection activities in mid-June 1985, we

found that the licensee had not apparently met the ASME Code requirements

relating to the signing of the Code Data Report (NPP-1) and the application of

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the ASME Code stamp to the hardware prior to the performance of the

hydrostatic test. We found little or no plans or correspondence to indicate

the responsibilities had been transferred t9 the installer or that the shop

welds or weld repairs were to be observed / inspected during the hydrostatic

test. Further, through records review and interviews (including the NRC SR1,

Dennis Kelley) we could not establish whether the required inspections were

performed in absence of the program, procedures, checklists, or instructions .

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In fairness to the NRC, the apparent lack of records associated with the

specific subassembly was included in the NRC inspection report as URI

(445/8507-07;446/85-05-09.) At that time, the licensee was, as a general

rule, given the "benefit of the doubt" and allowed time to recover records

needed to show "quality" of an activity in question. However, we had no real

assurance the inspections were performed.

On August 27, 1987, I called the U 5ES site to establish the status of the URI

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and confirmed that the item is still open. TheNRCapparentlyhasnotpt

brought this issue to a close af ter over 2 years have lapsed since the

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inspection exit with the licensee. Notwithstanding, the licensee may have

-performed a planned, comprehensive audit / review of this matter in the interim

period and taken adequate actions.

ARLOTTO REPORT

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Ouring the review of the Arlotto' report and reference documents, it became

apparent that the team concentrated on only the narrow,' limited, natter - the

deferral of the hydrostatic testing of the RCS loop 3 cold leg subassembly

until the performance of the main RCS hydrostatic test. I cannot comment on

why the issue was so limited in scope. The simple deferral of the hydrostatic

testing was not the safety issue. However, as the events (the OIA report and

reviews) evolved in time (the documentation provided to the Arlotto team from

Region IV and no interviews conducted to clarify the issues or to fully

understand the issues) it is not surprising that the scope was extremely

narrow in this particular instance.

CONCERNS AND SEQUENCE

This is the sequence of events, as I understand them. My concerns were

documented in a memorandum to Eric Johnson, dated August 12, 1986, including

"Issue 5" in the Arlotto report. As requested by Mr. Johnson, I provided

certain information in my August 12, 1986 memorandum, including the specific

concern, the facts and regulatory basis, the safety significance, and the

proposed disposition of the issue. I also provided a draf t written request

(under Mr. Johnson's signature) to HQ regarding the acceptability of deferring

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the hydrostatic of the cold leg subassembly, the signing of the ASME Code data

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package (NPP-1) prior to completing the package, and the acceptance criteria

and documentation requirements associated with the performance of the

hydrostatic test by the manufacturer or the installer. This interpretation-

was needed because our inspection efforts placed the licensee's program,

procedures, and practices (including the lack of records) in question.

Enclosure 1 of my August 12, 1986 memorandum contains the following

information:

Under Concern No. 1 - The information in the cold leg subassembly

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data package did not adequa*.ely address the code requirements-weld

and base metal repair inspections performed during a hydrostatic

test.

Under Inspection Facts - The subassembly had been stamped and the

hyt.sstatic test had not been performed. This was noted on the NPP-1

form. (Therefore we didn't know what to expect regarding records of

repairs and/or inspections in the NPP-1 provided by the

manufacturer.)

Under Safety Significance - The failure to require these inspections

during the performance of the ASME Code hydrostatic and the apparent

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failure to perform these activities leaves the ASME Code Class

piping in question.

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Under Disposition of the Issue - Ensure the timely followup

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of this specific concern by the NRC and the Applicant in a-

planned, systematic, and complete manner, as appropriate.

Enclosure 8 of my August 12, 1986 memorandum contains the following

information:

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Guidance concerning the acceptability of the performance of

hydrostatic testing of piping-subassemblies after installation.

into the system by the fabricator. Include the question of

signing the NPP-1 Form and stamp application prior to the hydro-

static test. Also address the responsibility of the manufacturer's

ANI.

Guidance regarding the acceptance criteria and documentation

requiresents during the performance of the systems hydrostatic test

by the manufacturer (shop) or the installer (field.)

It is important to note that, as far as my review could identify, my concerns

were not provided to the Arlotto team. Since I wasn't interviewed, there was

no way for Arlotto or me to reall:e that the safety issue as I saw it really

wasn't being addressed. This matter (Issue 5) was noted as removed from the

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NRC Inspection Report 50-445/85-07; 50-446/85-053 without being answered,in an

interview by 0IA in April 1986, pages 65-72 (Attachment C to the OIA Report.) -

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INSPECTOR'S CONCERN

A review of the interview of an inspector by OIA, pages 23-24, (Attachment G

of the OIA Report) states that the method of performing the hydrostatic- test

was questioned; however, the records reviewed indicated that the welds and

weld repairs may not have been checked as required by the ASME Code.

Further, as requested, the inspector provided his concerns to Mr. Martin / John

Davis in early 1987. This information was provided under cover letter to Mr.

Davis on January 20, 1987, by Mr. Martin. A review of this information

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(C9RRE-15, Enclosure 5) and discussions with the inspector revealed, again,

the basic safety question was not "adequately" addressed. It is extremely

important to realize that the B&R quality assurance procedure (CP-QAP-12.2,

Revision 8, paragraph 2.4) addressed vendor components; however, the procedure

did not mention piping subassemblies. Again, our inspection effort did not

reveal requirements to inspect shop welds or base metal repairs (none noted)

and included our discussion with Mr. Dennis Kelley (SRI) who had witnessed

part of the hydrostatic test. During the inspection, contacts included the

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B&R QA Manager, the B&R site QA Manager, and a number of other QAf B&R

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technical people. Af/ter about a week of NRC inspection effort the licensee

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could not explain the situation or prepnt the procedures, checklists, records' or

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interviews to alleviate our concernkg regarding eeting the basic ASME Code

requirements.

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GENERAL

The Arlotto Report does not adequately address two, significant concerns

relative to this issue. In the first place the matter does have a direct

safety significance since there was little or no evidence (written or oral),

regarding'the deferred hydrostatic test, that the licensee (or the

contractor) understood the ASME Code requirements nor accomplished the

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required inspections either intentionally or incidentally against some

preplanned acceptance criteria (ASME Code requirements). In the second place,

under Task 2, section 3.5, of the Arlotto report, the statement is made in

part, that considering the "worst case t hydrostatically test, was

subsequently installed... ruptured due to overstress. Therefore, worst case

has no safety significance... recommendations are unnecessary." This statement

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neive at best, and would have been better lef t out of the report.

CLOSING

Bob, in March 1986, I had indicated to you that, in my opinion, a real problem

existed in the DRSP in that findings were not being aggressively pursued. I

continue to believe that findings in 1984-1985 were not being handled

adequately. This may be a specific example of how significant findings were

not being pursued.

May I request that the specific issue regarding the RCS ASME Code hydrostatic

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< ~ test be reviewed and interviews be conducted with the appropriate persons to

L ensure the specific safety issue is appropriately addressed. Further, other

concerns related to inspections conducted (inclu g NRC IR No. 50-445/85-07;

50-446/85-05) may need addressed. These concerns Muld be obtained through

the reviews and interviews.

REFERENCE DOCUMENTS

Arlotto Report, dated 3/12/87 (CPRRG)

Issue #5 (Appendix A, pgs 3-14 and 3-15; Appendix B, pgs 60-62)

CPRRG-15, Enclosure 5

OIA Report 86-10, dated November 1986

Attachment C

Attachment G

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Memorandum For: Eric H. Johnson from D. R. Hunter,

dated August 12, 1986 (Concerns relating

specifically to NRC IR 50-445/85-07;

50-446/85-05, dated February 3,1986)

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0. R. Hunter