ML20198D510

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Partially Withheld Assessment of Allegations AQ-12,AQ-13 & AQ-115 to Allegation Category Qa/Qc 5E, Matls Re nonsafety-grade Matls Upgraded to safety-grade Through Use of Unauthorized Means
ML20198D510
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 06/07/1985
From: Livermore H, Watson V
NRC, NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM)
To:
Shared Package
ML20198C597 List: ... further results
References
FOIA-85-59, FOIA-85-89 NUDOCS 8605230312
Download: ML20198D510 (4)
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1. Allegation Category: QA/QC 5E, Materials
2. Allegation Number: AQ-12, AQ-13, AQ-14 and AQ-115 1
3. Characterization: It is alleged that nons'afety grade materials were up- ,

graded to safety grade through the use of interoffice memoranda or other l unauthorized means; that material was upgraded from one safety class to another; and that safety-related systems were downgraded to avoid inspec-tion by the Authorized Nuclear Inspectors (ANIS).

4. Assessment of-Safety Significance: The NRC Technical Review Team (TRT) reviewed Section 17.1.4, " Procurement Document Control," Section 17.1.7,

" Control of Purchased Material. Equipment and Services," and Section 17.1.8,

" Identification and Control of Materials, Parts, and Components," of the Final Safety Analysis Report (FSAR) for Comanche Peak Steam Electric Sta-tion (CPSES). Section 17, Table 17A-1 of the FSAR commits to the American Society of Mechanical Engineers (ASME) Code, including ASME Boiler and Pressure Vessel (B&PV), 1974 Edition and Summer 1974 Addenda for piping i and tubing, and Winter 1974 Addenda for component supports. ASME Section l NA-2134, " Optional Use of Code Class," paragraph (a), allows any item j classified as Class 2 to be constructed and stamped in accordance with code rule NB (Class 1). Paragraph (b) permits items classified as Class 3 to be constructed and stamped in accordance with the rules of NB or NC (Class 1 or 2). Sections NB-2551, " Tubular Products and Fittings," and NB-2530, " Examination and Repair of Plate," specify examinations required to meet the ASME Class 1 classification. If these examinations are per-formed and documented, the material may be upgraded (reclassified).

Brown & Root (B&R) procedure CP-QAP-8,5, Revision 4 and earlier revisions,

" Reclassification of Code Material," allows reclassification of either plate or pipe.

The ASME B&PV Code requires only that examinations be performed and docu-mented; it does not specify a particular method for documenting exami-nations. Nonconformance reports (NCRs) and interoffice memoranda (IMs) are lifetime records, as defined by ANSI N45.2.9, and are also on file in the permanent plant records vault (PPRV).

In assessing the allegations concerning material upgrades, the TRT reviewed 33 documentation packages of random heat numbers from the PPRV to assess the B&R program for reclassification of materials from one safety class to another. In these 33 packages, the TRT found only 1 material heat number

'that had been reclassified from Class 2 to Class 1 by an IM. This heat number, M20484, was reclassified by IM number 22,281 on December 8, 1981.

This IM documents that the requirements of the material specification and ASME Code, Subsection NF, Article 2000 had been met. The TRT reviewed the applicable code requirements and verified that the material was reclassi-fied in accordance with requirements. This IM also included ten other heat numbers that were properly reclassified. Both the engineer and .

quality assurance manager concurred with the reclassification.

Past practices at CPSES were to issue IMs documenting the approval to re-classify material to the PPRV. Although IMs are an acceptable method of documentation, they were discontinued as a means of documenting material reclassification activities with the issuance of CP-QAP-8.5, Revision 4 M5h" ~ 0-201 C ONtDESS-99. s PDR _ l .. s

(June 1984). The present system requires pipe and plate reclassification to be documented on a nonconformance report (NCR). The use of either memo-randa or NCRs to document material upgrade is consistent with ASME B&PV Code.

One of the allegations concerning the upgrade of nonsafety grade materials included the assertion that 70,000 IMs were issued to upgrade material _in the iron fabrication shop alone. This allegation is incorrect since only 27,541 IMs were written as of August 5,1984. _ Further, these IMs document actions by B&R in all areas which affected the project., not just material reclassification. The TRT reviewed 22 IMs choosen at random and verified that 21 different heats of material with the acceptable certified material test reports necessary to reclassify the materials used at the iron fabrication shop were on file in the PPRV.

It is also alleged that systems have been downgraded to less than safety related to avoid ANI review. In assessing this allegation, the TRT re-viewed all cases where systems were reclassified, a total of nine. Seven cases (design change authorization [DCA] 18,227, component modification card [ CMC] 39505, engineering change notice [ECN] 555, CMC 79822, design change review proposal [DCRP] 99,- DCA 4061, and DCA 15118) involved vent and drain lines open to the atmosphere. Since the lines are outside the last isolation valve, they are not subject to ASME requirements. In the eighth case, a class 3 piping system (MS-1-SB-019 R8) was extended to in-clude the downstream side of a moment restraint, which was previously un-classified. In the ninth case, the design of the diesel generator exhaust system was deleted from ASME B&PV code requirements. However, the diesel '

generator exhaust was seismically supported, as required for safety-related equipment.

Section NA3253 of the ASME B&PV code requires the owner or his agent to establish the code classification of items. All changes in ASME B&PV code classifications were reviewed and approved by the owner's agent, Gibbs &

Hill, the plant architect-engineer (AE). The TRT has verified by document review that these changes were consistent with the provisions of the ASME Code.

The TRT interviewed the ANI lead inspector, who stated that the owner or the AE establishes the ASME Code classification of safety-related items and that the ANI inspects in accordance with that ASME Code classification.

The ANI was not aware of any downgrading to less than safety-related to avoid ANI review. However, on a few occasions, safety related items had been reevaluated to determine whether an item should be corrected or whether a lower ASME Code classification would be acceptable. The latter, however, did not avoid an ANI review.

5. Conclusion and Staff Positions: Reclassifying material to upgrade it or downgrade it is acceptable when done in accordance with ASME Code. In implementing code _ requirements, Texas Utilities Electric Company (TUEC) has verified that materials have-had the required testing performed or that the required tests were performed under their approved program when materials were reclassified. The TRT verified, by review of certifie'd material test reports, that TUEC performed the necessary tests or verified that the tests were previously performed whether IM or NCRs were used. >

0-202

S Consequently, the TRT concludes that the TUEC reclassification of mate-rials program is acceptable.

The TRT verified that materials were classified from one safety class to another. However, the reclassification was performed in accordance with the ASME Code.

The TRT reviewed nine cases where TUEC upgraded or downgraded parts of systems based on a review of requirements. These changes were approved by the architect-engineer, as required. The TRT review did not substantiate the allegation that systems were downgraded to eliminate ANI inspections.

In a meeting with the alleger on December 10, 1984, the TRT presented the results of its assessment and the TRT's conclusion. Although the alleger was not wholly satisfied with the conclusion reached, the TRT has no further technical concerns regarding the resolution of this allegation.

7. Attachments: None.

Reference Documents:

1. CPSES/ Final Safety Analysis Report.
2. B&R Procedure CP-QAP-8.5, Rev. 4.
3. ANSI N45.2.9.
4. Interoffice Memos: IM-22179, IM-22138, IM-22175, IM-22245, and IM-2281.
5. Drawings: SI-2-RB-13-4, SC-1-513-032, CT-1-SB-14, CC-L-SB-042, BR-1-SB-05, SPOOL IQ3, BR-1-SB-004, SPOOL IQ3, BR-1-SB-006, MS-1-SB-050, and CC-2-SB-042 ITTI.
6. Design changes: DCA 4061, DCA 18227, CMC 39505, ECR 555, CMC 79822, DCRP 99, and DCA 15118.
7. Nonconformance reports (NCRs) M3778 and M3390.
8. Gibbs & Hill Specification 2323-MS-43A, Rev. 4.
9. Procedure CP-QAP-8,5, Rev. 4.
10. Procedure CP-QAP-8.1 Rev. 8.
11. ASME B&PV Code NB 2510, NB 1510(2), NB 2510(b), NA-2134(a),

NA 2134(b), NB 1551, and NB 2530.

12. AQ-12; March 7, 1984, letter item 9; A-3 statement and interview, pp. 26-34.
13. AQ-13; GAP petition, March 9, 1984; A-3 statement and interview pp. 55-60; August 1,1984, pp. 24-25.
14. AQ-14: GAP petition March 19, 1984; A-1 statement and interview pp. 48-51; August 1, 1984, interview pp. 24.
15. Meeting with A-1 and A-3, December 10, 1984, pp. 101-103.
8. This statement prepared by: 1m,Ld.h b 6[6b5 V. Watson, TRT Dat'e '

Technical Reviewer 0-203 i

I s-I Reviewed by: c/2 m (A p_ g%.Jb _

'H. Livermore Date Group Leader 1

Approved by:

V. Noonan Date Project Director d

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