TXX-3544, Responds to NRC 820628 Telcon Re Violations Noted in IE Insp Repts 50-445/82-10 & 50-446/82-05.Corrective Actions:Moment Limiting Restraints Received Reinspected & Relevant Indications Reworked

Responds to NRC 820628 Telcon Re Violations Noted in IE Insp Repts 50-445/82-10 & 50-446/82-05.Corrective Actions:Moment Limiting Restraints Received Reinspected & Relevant Indications Reworked

ML20071M362
Person / Time
Site:	Comanche Peak
Issue date:	07/19/1982
From:	Gary R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	Madsen G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20071M359	List: TXX-3544, Responds to NRC 820628 Telcon Re Violations Noted in IE Insp Repts 50-445/82-10 & 50-446/82-05.Corrective Actions:Moment Limiting Restraints Received Reinspected & Relevant Indications Reworked
References
TXX-3544, NUDOCS 8209270099
Download: ML20071M362 (3)

Text

• '

'. . TEXAS UTILITIES GENERATING COMIMNY 2tXII DRYAN TOW EH t>AILAS.TE,X AM 7th20t af;$h;$b;;;' July 19, 1982 TXX-3544 Jtt gg g Mr. G. L. Madsen, Chief .i i g

~

r .,

Reactor Projects Branch .

U.S. Nuclear Regulatory Commission Office of Inspection and Enforcement 611 Ryan Plaza Drive, Suite 1000 Docket Nos. 50-445 Arlington, TX 76012 50-446 COMANCHE PEAK STEAM ELECTRIC STATION RESPONSE TO NRC UNRESOLVED ITEM INSPECTION REPORT N0. 82-10/82-05 FILE N0: 10130

Dear Mr. Madsen:

As agreed in a telephone conversation on June 28, 1982, between the TUGC0 QA Manager and Mr. E. H. Johnson of your staff, we submit this letter which describes our corrective actions with respect to welding inspections at the Chicago Bridge & Iron Company (CB & I). Although the matter in question (as identified in NRC I & E Report 50-445/82-1050-446/82-05) involves recent allegations regarding pipe whip restraints, this discussion also covers prior corrective action taken with regard to piping moment limiting restraints manufactured at the same facility.

As early as July,1980, the CPSES QA _ Program had identified an apparent violation of NDE procedures at Chicago Bridge & Iron Company. The matter was discovered during a routine audit / source inspection by Brown & Root QA at the CB & I Salt Lake City facility and involved moment limiting restraints. The auditor identified some welds on the restraints to have surface conditions unsuitable for proper interpretation of magnetic particle test (MT) results. The NRC investigated the matter (see NRC I & E Report 80-20) and issued a citation for violation of NDE procedures.

All moment limiting restraints received at the jobsite up to the date of I & E Report 80-20 were reinspected, and relevant indications were reworked to achieve full compliance. In addition, our source inspection program at that time began placing more emphasis on detecting weld surface conditions of the type identified by the Brown & Root auditor.

From that time until early 1962, our source inspections at the CB & I Salt Lake City facility continued to identify relevant welding indications on moment limiting restraints and pipe whip restraints. During this time TUGC0 management became increasingly concerned that TUGC0 inspectors were having to do basic, first-line inspection work that CB & I should have been doing.

8209270099 820915 DRADOCK05000g

6 .

Mr. G. L. Madsen, Chief Page 2 July 19, 1982 In March,1982, upon the recommendation of the TUGC0 Vendor Compliance Supervisor, the TUGC0 QA Manager authorized a trip to the CB & I facility in Salt Lake City to observe a source inspection and meet with their management. TUGC0 was represented by the TUGC0 QA Vendor Compliance Supervisor, who met with their plant management. CB & I was told by the TUGC0 Supervisor that unless their inspections were made more effective, we would no longer identify individual weld indications to them so that they could be reworked and released at that time. Instead, we would simply reject all welding on an individual restraint upon identifying a relevant indication and thus force their inspectors to thoroughly reinspect the entire assembly until finding the indication themselves.

Further corrective action with regard to CB & I was initiated as a result of discovering some relevant indications on four pipe whip restraints which had been sandblasted after arriving on site. We then directed a reinspection of 52 other restraint assemblies, which had been received on site prior to or subsequent to the four initially inspected. These inspections revealed condi-tions similar to those on the four restraints, but to a lesser degree. The specific corrective actions were as follows:

1. On May 5, 1982, the TUGC0 QA Manager telephoned the president of CB & I and requested his personal involvement in the matter.

2. As a result of that conversation, a meeting was called at the jobsite on May 7.1982, with CB & I and CPSES management. At this meeting the following commitments were made:

A. A Brown & Root welding specialist would be assigned full-time to the CB & I shop for at least six weeks to monitor welding and NDE. He arrived there on May 10, 1982. He will remain there full-time at least until August 1,1982, at which time we will determine whether his full-time status can change.

4 B. CB & I committed to sandblast all welds prior to inspection even though this is not required by ASME Section III, Subsection NF, or by the specification.

C. CB & I agreed to perform MT on weld areas randonly selected by TUGC0 QA inspectors, over and above the 100% MT already done prior to the arrival of the TUGC0 personnel.

D. CB & I agreed to perform a post-sandblast visual inspection of 100% of the welds prior to TUGC0 QA's 100% visual inspection.

The above listed corrective actions have brought about a significant improvement in CB & I's inspection performance. Please note that we have evaluated the welding indications which are a matter of record and have

)

m lc -

Mr. G. L. Madsen, Chief

~Page 3 July '9, 1982 determined that the matter would have had no significance, assuming they had gone uncorrected. We :.ill continue to monitor this facility. Should.

you require additional information, please advise.

Very truly yours, 4p.

R. Gary RJG:pko E

!