ML20198D507

Partially Withheld Assessment of Allegation AQ-41 to Allegation Category Qa/Qc 5E, Matls Re safety-related Pipe Section Sandblasted on Outside in Preparation for Use & Markings Used for Traceability Removed

ML20198D507
Person / Time
Site:	Comanche Peak
Issue date:	06/07/1985
From:	Livermore H, Watson V NRC, NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM)
To:
Shared Package
ML20198C597	List: IA-85-517, Partially Withheld Assessment of Allegation AQE-41 to Allegation Category Qa/Qc 6, QC Insp Re Worn Gauges Used to Calibr Lighting Restraint Cable Tools Resulting in Incorrect Installation & Issuance of Nonconformance Rept ML20198C594 ML20198C616 ML20198C640 ML20198C704 ML20198C711 ML20198C794 ML20198C831 ML20198C859 ML20198C871 ML20198C883 ML20198C897 ML20198C933 ML20198C974 ML20198D040 ML20198D103 ML20198D141 ML20198D170 ML20198D231 ML20198D267 ML20198D290 ML20198D314 ML20198D348 ML20198D373 ML20198D377 ML20198D391 ML20198D411 ML20198D419 ML20198D424 ML20198D427 ML20198D432 ML20198D437 ML20198D445 ML20198D450 ML20198D460 ML20198D471 ML20198D479 ML20198D487 ML20198D492 ML20198D507 ML20198D510 ML20198D523 ML20198D529 ML20198D534 ML20198D545 ML20198D554 ML20198D559 ML20198D565 ML20198D576 ML20198D585 ... further results
References
FOIA-85-59, FOIA-85-89 NUDOCS 8605230309
Download: ML20198D507 (2)

Text

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1. Allegation Category: QA/QC SE, Materials

2. Allegation Number: AQ-41

'3. Characterization: A concern was identified that safety-related pipe sec-tions were sandblasted on the outside in preparation for use and the mark-ings used for traceability were removed.

4. Assessment of Safety Significance: In assessing this allegation, the NRC Technical Review Team (TRT) reviewed Brown & Root (B&R) procedure CP-CPM-

-6.9, Revision 0, dated October 6, 1978. Paragraph 3.5.4.4 of this proce-dure requires positive identification of heat / code markings prior to cut-ting pipe for fabrication. This paragraph states in part, "Under no cir-cumstances may piping materials without heat number and code traceability be used for ASME fabrication."

The TRT reviewed 22 pipe spool assembly documentation packages and 12 receiving inspection pipe documentation packages to ascertain if any of the pipes _were sandblasted. The packages selected were for safety-related material. The TRT did not find any indication of sandblasting of the-outside surface of, the piping, which would have been indicated _in the documentation packages if it-were required. The TRT also physically in-spected 32 pieces of piping at the Comanche Peak site for identification and method of identification. Identification was visible on the outside of the pipe and had been applied b'y paint stick or steel stamping. There ,

.was no evidence of sandblasting of the outside surface on any of the bulk piping stock inspected.

The TRT conducted a surveillance inspection of the pipe fabrication shop (PFS), interviewed several shop employees and verified that there are three main categories of piping material that are routinely sandblasted.

This was also verified in NRC Region IV inspection report 50-445/79-11.

The three categories are:

1. Completed carbon steel spool pieces, which are sandblasted on the outside prior to painting. These pieces are normally identified by an attached stainless steel band on which the identity is encoded by steel stamping. (Refer to paragraph 3.4 of QI-QAP 11.1-5, Revi-sion 0.) Should the tag be mutilated or lost, the identity of the piece can be reestablished since each spool is unique and is fully

. described by its isometric drawing.

! 2. Carbon steel pieces cut to length, but otherwise in an unfabricated condition. These pieces are sent to sandblasting to have the inside cleaned prior to further fabrication. The outside surface of the pipe, which is not sandblasted, carries the heat markings.

i 3. Bulk carbon steel pipe materials used for making equipment stands l and supports are sandblasted and painted prior to fabrication. This material is used in nonsafety-related systems.

l If b'ulk' pipe were sandblasted on the outside surface (which would be in

! violation of the practices described above, with the exception of item 3) and if the. identification were removed and could not be reestablished by 85d52 0-199 me.-.c_ m m-

heat number or physical dimensions, it would be turned over to the quality control inspector, who would process the piece per procedure CP-cpm-6.9.

During its investigation, the TRT observed that all pipe to be used for safety-related systems which was examined in the PFS was sufficiently identified. These materials were also subjected to a system of quality control verification per procedure QI-QAP-11.1-5 during fabrication to preclude improper or unidentified material being used or installed in a safety-related system.

5. Conclusion and Staff positions: The TRT reviewed the procedures in effect at the time of the allegation and those currently in force, and confirmed that there are sufficient quality checks and verifications to prevent the use of unidentified bulk pipe material from being installed in safety-related systems. The procedures in effect are adequate for the control of n aterial and, if effectively implemented, should prevent the loss of traceability.

The source of this concern was not an alleger; therefore, an exit interview was not conducted. __

7. Attachments: None.

Reference Documents:

1. B&R procedure CP-CPM 6.9, Revision 0, dated October 6,1978.

2. B&R procedure QI-QAP 11.1.5, Revision 2, dated August 28, 1980.

3. Region IV report IR 50-445/79-11.

8. This statement prepared by: J.xmyw,d.U)Me V. Watson, TRT ChPT Daf.e '

Technical Reviewer

^

Reviewed by: mu<a 5-_ 6 5 H. Livermore Date Group Leader Approved by:

V. Noonan Date Project Director 0-200 i

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