IR 05000445/1985007

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)

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4,, ,, ARLINoToN. TEX AS 76011 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 perfonne 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 g 30 g 2 880203 fo%$- $7-477 AIROZ087-677 PDR D/4

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-2-quality issues. The compliance with the ASME Code had not been specifically looked at during previous NRC/TRT activitie It was deemed to be extremely important to review this area. Del Norman was selected to look at this particular are 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 tes 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 questio However, we had no real assurance the inspections were performe 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 ope 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 action 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 tes 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 instanc 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 issu I also provided a draf t written request (under Mr. Johnson's signature) to HQ regarding the acceptability of deferring

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A 4-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 installe This interpretation-was needed because our inspection efforts placed the licensee's program, procedures, and practices (including the lack of records) in questio Enclosure 1 of my August 12, 1986 memorandum contains the following information:

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

data package did not adequa*.ely address the code requirements-weld and base metal repair inspections performed during a hydrostatic tes *

Under Inspection Facts - The subassembly had been stamped and the hyt.sstatic test had not been performed. This was noted on the NPP-1 for (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 questio ,

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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 appropriat 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 installatio into the system by the fabricato 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 AN *

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 tea 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 addresse This matter (Issue 5) was noted as removed from the Y k 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 Cod Further, as requested, the inspector provided his concerns to Mr. Martin / John Davis in early 198 This information was provided under cover letter to M Davis on January 20, 1987, by Mr. Martin. A review of this information W

(C9RRE-15, Enclosure 5) and discussions with the inspector revealed, again, the basic safety question was not "adequately" addresse 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 sd B&R QA Manager, the B&R site QA Manager, and a number of other QAf B&R r

technical peopl 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-f f~

interviews to alleviate our concernkg regarding eeting the basic ASME Code requirement , _ - - - __ __

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-7-GENERAL The Arlotto Report does not adequately address two, significant concerns relative to this issu 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 opp 4Aa b k g

neive at best, and would have been better lef t out of the repor 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 pursue I continue to believe that findings in 1984-1985 were not being handled adequatel This may be a specific example of how significant findings were not being pursue 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 addresse These concerns Muld be obtained through the reviews and interview 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 i

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)

NL 0. R. Hunter