ML20147E515
| ML20147E515 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 08/12/1986 |
| From: | Hunter D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Johnson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20147E473 | List: |
| References | |
| FOIA-87-677 NUDOCS 8803070089 | |
| Download: ML20147E515 (18) | |
See also: IR 05000445/1985007
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AUG 12 586
I:El;0RANLUM FOR:
Eric H. Johnson. Director
Division of Reactor Safety and Projects
FROH;
D. R. Hunter, Chief, Reactor Project Sectico B, RPB
SUBJECT:
FOLLOWUP ON INTERVIEW WITH NRC INSPECTION PERS0hWEL
ASSIGNED TO THE COMANCHE PEAK STEAM ELECTRIC GENEP.ATING
STATION (CPSES)
REFERENCE:
ilRC IR h0. 50-445/85-07; 50-446/85-05, dated Feuruary 3, 1985
Meeting on February 25, 1986, sone subject
Memorandum, E. H. Johnson to D. R. Hunter, dated
March 25, 1986
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Memorandum, E. H. Johnson to 0. R. Hunter, dated
June 5, 1906
As requested in your March 25, 1986, memorandum, and the later request in your
June 5,1986, memorandum this documents the concerns related specifically to
the CPSES NRC Inspection Report flu. 50-445/85-07; 50-446/85-05, dated
February 3,1986. As the Chief, CPSES group, I directed and concurred in the
inspection plan and approved the inspection findings. These findings were
relayed to the licensee at the conclusion of the inspection.
The items of concern regarding the subsequent handling of inspection findings
were relayed to you for your consideration during discussions prior to the
Februa ry 25, 1986, meeting conducted in your office. The February 25, 1986,
meeting included certain other Region JV DRSP personnel, including myself and
Delmer Norman.
The items vi concern regarding the handling of inspection
findings were again discussed in som detail.
Enclosures 1 through 7 to this memorandum address, as I understand the
findings, my concerns.
Enclosures 8 and 9 are draf t memoranda requesting
consideration be provideo regarding the ASME Code requirements and applicart
comitments to these requirements.
I appreciate your :onsideration regarding the items of concern and your
support in obtaining the needed consideration ano assistance regarding the
AS!!E Code questions.
' p o w % .y. g ,.,
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D. R. Hunter, Chief
Reactor Project B, RPB
Enclosures:
As stated (9)
Attachment:
cc:
Oraft NRC IR No. 50-44585-07;
R. D. Martin, RA
50-446/65-05
S. Connelly, 01A
J. E. Gagliardo, C/RFB
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Enclosure 1
Concern No. 1 of 0. R. Hunter
Signoff of the ASME Code NPP-1 data form for the Reactor Coolant Pressure
Boundary (RCPB) system cold leg subassembly by the manufacturer and ANI and
the application of the code stamp to the piping subassembly prior to the
completion of the required ASME hydrostatic test. The information contained in
the cold leg subassembly data package did not adequately address the code
requirements - weld and base metal repair inspections performed during a
hydros itic test.
Inspecc. ion Facts and Regulatory Basis
(Reference - Oraft report, item 14.c (3) on pages 17 and 18 (URI
446/85-05-12) - attached)
The normal program inspection of the RCPB system was performed to verify the
compliance with comitments to the ASME Code,Section III,1974, edition
through sumer 1974, addenda, as referenced in the FSAR, Table 5.2-1.
The inspection of selected records and procedures was conducted regarding the
cold leg (piping subassembly considering the ASME; Section 111 requirements -
NB 6114 aj, component tests under NB-6221 (a); NB 6221 (a), hydrostatic
testing of completed components prior to installation in the system; NB 6221
(b), pressure test requirements for conponents within the overpressure
protection devices; NB-6221 (c), substitution of the systr.m test for the
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component test; N8-6115, pressure testing, signing of the Data Report Form and
stamp application; and NA 8231, stamp application after the hydrostatic test.
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The inspection revealed that the NPP-1 Form for the cold leg subassembly had
been completed and signed by the manufacturer and Authorized Nuclear Inspecter
and the same Code Stcmp had been applied to the item prior to completion of
the same hydrostatic test and inspections of shop welds and base matal
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repairs.
The inspection revealed that the lack of the performance of the
hydrostatic test was noted on the NPP-1 form; however, no further 'ormal
documentation or comunication between the manufacturer and the fabricator was
identified.
Safety Significance
The required inspections and acceptance of the shop welds and base metal
repairs were apparently not performed by the manufacturer even though the
NPP-1 Form was signed and the ASME Code Stamp was applied.
No formal
comunication between the manufacturer and the installer was noted to insure
the required hydrostatic test and inspections were perfomed and witnessed by
an ANI; therefore, completing the code data package and providing validity to
the ASME Code Stamp. The failure to adequately perfom these activities leaves
the ASME Code Class piping quality in question - en unacceptable practice and
not in accordance with the regulatory requirements and comitments.
This
finding may be indicative of a QA Program breakdown in the area.
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Enclosure 1
Disposition of Issue - Previous Haridling/Apprcpriateness
Tha entire inspection activity documentation, paragraph 14.c (3), including
the inspection acceptence criteria, inspection documentation, and the
unresolved matter was deleted from the report.
The questionable practice
utilized at CPSES for both Unit 1 & 2 (unresolved pending further evaluation...
445/8507-07; 446/8505-13 - draft report), may not receive adequate staff
evaluation in order to disposition this matter. A documented NRC staff
position regarding this industry practice was deemed appropriate because of
the apparent generic implication! associated with this matter.
Both the
lice ,see and the NSSS venoor were knowledgeable of the practice.
The disposition of the stated concern would appear to include the following
actions:
Obtain a written NRC staff position regarding the licensee / industry
practice.
Provide for inspection program upgrade and inspector trdining, as
necessary to address this concern.
Provide supervisory training to instill in all supervisors the
importance of understanding inspection findings and supporting
first-line inspectors.
Ensure inspection findings which are included in an inspection
report have received the "blessing" of the involved inspectors
or the differences are well understood and documented.
Ensure the tinely followup of this specific concern by tha NRC
and the applicant in a planned, systematic, and complete manner,
as appropriate.
I have no further coraTent as to the appropriateness of the management
disposition of this concern.
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Enclosure 2
Ccocern No. 2 of 0. R. Hunter
identified discrepancy noted between the licensee comitments in the FSAR to
the ASME Code and the ASME Code certified in the NPP-1 Code Data Report form-
for the cold leg subassembly.
Inspection Facts and Reculatory Basis
-(Reference - Draft report, item 14.b (2) on page 17
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(URI 446/8505-11) - attached)
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Th.; normal program inspection of the RCPB system was peformed to verify the
applicant's system for preparing, reviewing and maintaining records for the
RCPB piping and components; that selected records reflected compliance with
the NRC requirements and SAR connitments for manufacturer, test and
installation .of the items, and that as-built hardware was adequately marked
and traceable to records.
The inspection of selected records and procedues regarding the cold leg piping
subassembly manufacturer records (Sandusky Foundary and Machine Company and
Southwest Fabrication and Welding Company) revealed that the subassembly was
certified to ASME Section !!!,1974 edition through winter,1975. The FSAR
consnitment (Table 5.2-1) was ASME Section 111, 1974, edition through sunner,
1974.
Safety Significance
The full safety significance of this issue and the generic implications can
only be determined after the cause of the deficiency is identified and fully
understood.
The failure to adequately certify the RCPB to the applicable ASME Code
commitments is a poor practice and not in accordance with the NRC requeements
and consnitments.
This finding may be indicative of a QA Program breakdown in
the area.
Disposition of Issue - Previous Handling / Appropriateness
The unresolved item was deleted and the item noted as acceptable. No basis
for this was providt 1
Furthermore, the item as documented in the inspection
report remains in erior in the final inspection report (item 14.b. (1) on page
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18).
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The disposition of the stated concern would appear to involve the following
actions:
Review the FSAR change submitted and approved by the NRC staff
subsequent to the inspection.
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Enclosure 2
Determine the root cause' and generic implications of the discrepancy,
including-the lack of ottention to detail by the licensee.
Document the inspection findings to complete the record in the
public document room.
Provide staff training to emphasize the importance of being accurate
regarding inspection findings.
Ensure the timely followup of this matter in a planned and systematic
runner by the licensee and the NRC.
I have no further comment as to the appropriateness of the management
disposition of this concern,
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Enclosure 3
Concern No. 3 of D. R. Hunter
The lack cf engineering documentation associated with the CPSES Unit '.
Reactor Pressure Vessel (RPV) installation. The cited violation of Criterion
111 of appendix B_ to 10 CFR 50 was downgraded to an unresolved item. The
basis for the downgrade was not apparent.
Inspection Facts sand Regulatory Basis
(Reference - Draf t report, item 12.a. on page 13 (446/8505-06) - attached)
The normal program inspection included the review of selected records
associated with the placement of the Unit 2 RPV. The decislun to inspect the
Unit 2 RPV placement was also made because the activity was one of the QA/QC -
Centention 5 items.
The inspection of selected records, procedures, drawings, ano the RPV
installation traveler revealed the lack of adequate placement criteria for the
RPV.
The matter was noted as a violation of Criterton III of Appendix B to
10CFR50 (other general QA program requirements apply - e.g., Criterta II, V,
VI, XV, and XVI).
Safety Significance
This issue is extremely significant in that the finding indicated that the
program, procedures, and practices were not adequate regarding the RPV
placement specifically. Even more significant is that the finding indicated
the potential lack of adequate program, procedures, and practices regarding
the placement of other major equipment at CPSES.
The failure to provide adequate controls during the placement of the Unit 2
RPV was not in accordance with basic regulatory requirements and comitments.
The licensee apparently did not insure adequate controls during the placement
of a major piece of equipment such as the RPV, and it is not likely that
adequate controls were provided concerning the placement of other
safety-related equipment at CPSES. This finding is indicative of a QA Program
breakdown in this area.
Disposition of Issue - Previous Handling / Appropriateness
The cited violation was downgraded from a violation to an unresolved item;
therefore, the licensee management has not been required to address the
specific item, generic implications and root causes.
The handling of the item
as dn unresolved item does not elevate the matter to the appropriate levels of
licensee and NRC management.
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' Enclosure 3
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The disposition of the issue wculd appear to include the following actions:
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Review the issue to determine the scope and depth of this problem.
Determine the root causes and generic implications.
Insure the timely followup of this matter in a planned and
systematic manner by the licensee and the NRC.
Provide staff training to emphasize the importance of providing
an adequate basis for inspection findings.
I have no further comment as to the appropriateness of the management
disposition of this concern.
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Concern No. 4 of D. R. Hunter
The failure to document nonconformino conditions and engineering aev14tions
associated with the Unit 2 Reactor t. essure Vessel (RPV) placenent. The cited
violation of Criterion XV of Appendix B to 10CFR50 was cowngraded to an
unresolved item. The basis for the downgrade was not apparent.
Inspection Facts and Regulatory Requirements
(Reference - Oraf t report, item 12.b on page 13 (446/8505-07) - attached)
The normal progrom inspection included the review of selected records
associated with the placement of the Unit 2 RPV.
Tne decision to inspect the
Unit 2 RPV placement was also made because the activity was one of the QA/AC -
Contention 5 items.
The inspection of selected records, including the "operation traveler"
assoCidted with the placement activity, revealed that the as-built, documented
clearances (support bracket and support shoe) exceeded both the original
recomended and field-revised tolerances.
The noted nonconfonning conditions
and the engineering devi4tions were not adequately dispositioned, including
evaluation and documentation as required by basic QA program requirements
(e.g. , Criteria XV, XVI, V, and VI).
Safety-Significance
This specific issue is significant in that the finding indicated that the
program and the procedures were not adequate regarding the control and
disposition of noted nonconforming conditions and engineering evaluations
associated with the Unit 2 RPV placement.
The generic implications of this
finding are estremely significant, indicating a potential breakdown in the QA
Program concerning the identification, documentation, and disposition of noted
nonconforming conditions (e.g., Criteria II, V, VI, XV, XVI, and XVII).
The failure to provide adequate control and disposition of noted
nonconformances during the placement of the Unit 2 RPV was not in accordance
with basic regulatory requirements and comitments.
The licensee apparently
did not ensure adequate control and disposition of noted nonconfonnances
during the placement of a major piece of equipment such as the RPV, and it is
noc likely that such adequate controls were provided during the placement of
other safety-related equipment at CPSES.
Disposition of Issue - Previous Handling / Appropriateness
The cited violation was downgraded from a violation to an unresolved item;
therefore, the licensee management has not been required to address the
specific item, root causes and generic implications.
The handling of the item
as an unresolved item does not elevate the matter to the appropriate levels of
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iicensee and NRC management.-
Tre' disposition of the issue would appear tu include the following actions:
Review the issue to_ determine the scope and cepth of this problem.
Ensure the timely followup of this matter in a planned and
systematic manner by the licensee and the NRC.
Provide staff training to emphasize the importance of providing
an adequate basis for inspection findings.
I have no further comment as to the appropriateness of the inanagement
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Enclosure 5
Concern No. 5 of D. R. Hunter
The failure to perfom auotts or surveillances of Unit 2 Reactor Pressure
Vessel (RPV) placement. The cited violation of Critericr. XVIII of Appendix B
to 10CFR50 was downgraded to an unresulved item. The basis for the downgrade
was not apparent.
Inspection Facts and Regulatory Gequirements
(Reference - Draf t report, item 12.d. on page 14 (446/8505-08) - attached).
The normal program inspection included the review of selected records
associated with the placement of the Unit 2 RPV. The decision to inspect the
Unit 2 RPV placement was also made because the activity was one of the QA/QC
Contention 5 items.
The inspection of the placement of the RPV, through record reviews, included
the review of any or all available audit or surveillance reports which had
been perfonned during the RPV placement (e.g., placement criteria, procedures,
travelers, hardware placement, and as-built records).
No audits or
surveillance reports were made available. There was no evidence that
audits or surveillances had been perfomed by the applicant in this area as
required by basic QA program requinnents(e.g., Criteria I, II, and X
VIII).
Safety Significance
T."is specific isse 9
ionificant in that the finding indicated that the
program and procer ses werd cot adequate regarding the implementation of the QA
audit and/or survet!1ance program concerning the Unit 2 RPV placement
activities. The generic implications of this finding are extremently
significant, indicating a potential QA program breakdown concerning major
equipment installation. This finding is also similar to the findings made by
the TRT-QA/QC group and by the Region IV task group (NRC NO. 50-445/84-32;
50-446/84-13) in these and other major areas.
The failure to provide adequate audit and/or surveillance during the placement
of the Unit 2 RPV was not in accordance with basic regulatory requirements and
cocinitments. The licensee apparently did not ensure adequate audits and/or
surveillance during the placement of the RPV and it is not likely that such
adequate audit and/or surveillance activities were provided during the
piecement of other safety-related equipment at CPSES.
Disposition of Issues - Previous Handling / Appropriateness
The cited violation was downgraded from a violation to an unresolved item;
therefore, the licensee management has not been required to address the
specific item, generic implications, and root causes.
The handling of the
itein as an unresolved item does not elevate the matter to the appropriate
levels of licensee and NRC management.
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Enclosure 5
--The disposition of the issue would appeer to include the following acticas:
Review the-tssue to determine the scope and depth of the problem.
Ensure the timely followup of this matter in a ' planned and systematic
manner by the-licensee and the NRC.
Provide' staff training to emphasize the importance of providing an
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adequate basis for inspection findings.
- 1 have no further comment s to the appropriateness of the management
- dispositon of~this concero.
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Enclosure 6
Concern No. 6 of D. R. Hunter
The failure _to adequately identify spool piece material. The cited violation
of Criterion VIII of Appendix B to 10CFR50 was downgraded to an acceptable
This
finding - subsequent to the completion of the inspection period.
practice appears to be questionable at best.
Inspection Facts and Regulatory Requirements
(Reference - Draf t report, item 14.b. on page 16 (446/8505-09) - attached)
The nonnal program inspection of selected ASME code piping and components was
perfonned to verify the applicants system for preparing, reviewing, and
maintaining records for piping and components; that selected records reflected
compliance with the NRC requirements and SAR coninitments; and that selected
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as-built hardware was adequately marked and traceable to the records.
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The inspection of a CVCS spool piece (3Q1) was selected because the item was
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field-fabricated from bulk material and installed in the system.
inspection was to specifically verify the licensee practices regarding the
field fabrication, material division, and identification (markings) to be in
accordance with the ASPE code requirements (NA-3766) and Criterion VIII and
Appendix B to 10CFR50.
Safety Significance
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The full safety significance of this issue cannot be detemined at this time
because the acceptance criteria and the finding are no longer documented in
Additional samples taken to confim the acceptability
the inspection report.
of the licensee's program, procedures, and practices in this area. The
spool piece marking was not apparent during the inspection and the available
documentation of the item was less than expected - at best.
This specific finding, again, demonstrated the less than acceptable and
adequate licensee quality assurance practices concerning the ASME code
requirements.
Disposition of Issue - previous Handling / Appropriateness
The cited violation was downgraded to an acceptable item. No basis was
documented for this decision.
The apparent acceptability of the item was
determined af ter the completion of the inspection period. This additional
inspection effort is not apparent.
The failure to continue this finding has
prevented the further review of the area by the licensee and the NRC.
The disposition of the issue would appear to include the following actions:
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Reviaw the issue to determine the scope and depth of the problem.
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Ensure the timely followup of this matter in'a planned and
systematic nunner by the licensee and the NRC.
NRC should-followup on the handling of the' finding subsequent to the-
documented inspection period.
Staff training should'be provided to emphasize the.importance of
providing an adequate basis for inspection findings in a timely
manner.
I have no further comment as to the appropriateness of the management
disposition of this concern.
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Enclosure 7
Concern No. 7 of D. R. Hunter
The failure to adequately maintain retrievable records associated with the
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Loop 3 RC Cold Leg piping subastembly as required by Criterion XVII of
Appendix B to 10CFR50. The finding was downgraded to an acceptable finding -
subsequent to the completion of the inspection period.
The basis for the
downgrade was not apparent.
Inspection Facts and Regulatory Reouirements
(Reference - Draft report, item 14.c. (1) on page 17 (446/8505-10) - attached)
The normal program inspection of selected reactor coolant pressure boundary
(RCPB) systems was perforwed to verify:
the applicants system for preparing,
reviewing, and maintaining records for the RCpB piping and components; th:t
selected records reflected compliance with the NRC requirements and SAR
cannitments for nanufacturer, test, and installation of items; and that
as-built hardware was adequately marked and traceable to records.
Tne inspection of selected records regarding the Cold leg piping subassembly
revealed that the CMTRs for the 22-degree elbow, 10-inch 45-degree nozzle, and
the 21-inch therrowell bosses were not available for inspection. Some weeks
af ter the completion of the inspection the records were apparently made
available to the NRC inspectors. After reviewing these records the findings
were cleared from the inspection report.
During the inspection period, the records of these major safety-related
activities were not readily retrieveable (provided by the applicant) as they
should be, in accordance with the requirements - Criterion XVII of Appendix B
to 10CFR50 and RG 1.88/ ANSI N 45.2.9 and applicant's SAR commitrents.
Safety Significance
The full safety significance of this issue cannot be determined at this time
because the findings and documentation were removed from the inspection
report. Notwithstanding, the failure to have retrieveable documentation of
significant safety-related activities identifies a potentially significant
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generic problem in the area of documentation of the safety-related
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activities. The generic implications of this finding are enorwous.
Disposition of Issue - previous Handling / Appropriateness
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The cited violation was downgraded to an acceptable item. No basis was
docurented for this decision and the acceptability was determined after the
end of the inspection period.
The additional inspectiod effort is not
apparent.
The failure to continue this finding has prevented the further
review of the area by the licensee and the NRC.
The disposition of the issue would appear to include the following actions:
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Enclosure 7
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Review the issue and determine the scope and depth of the problem.
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Ensure the timely followup of the matter in a planned and systematic
manner by the licensee and the NRC.
NRC should followup on the handling of the finding subsequent to
.the end of the documented inspection period.
Provide staff training to emphasize the importance of providing
an adequate bats for inspection findings in a timely manner.
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Enclosure 8
f4EMORA?!CUti FOR:
J. G. Partlow Of rector. Division of Inspection Programs
FR0ll:
E. H. Juhnson Director, Division of Reactor Safety and
Projects RIV
SUBJECT:
CLARIFICATION OF CODE REQUIREMENTS CONCERNING REQUIREMENTS
FOR HYOROSTATIC TESTING CLAT.S 1 PIPING SUBASSEMBLIES AT
COMANCPE PEAK ELECTRIC STATION (CPSES)
During the routine of th_ Reactor Coolant Pressure Boundary (RCPB) piping two
concerns were identified. First, it was observed that the required
fabrication "shop" hydrostatic tests of the Class 1 piping subassemblies
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(ASME,Section III,1974 edition through winter 1975 addenda) had been
deferred until the field "system" hydrostatic tests. Discussions with the
NSSS subcontractor and site constructor / installer revealed this to be the
"normal practicc".
Based on a review of the ASME Code by the project, it appears that a "shop"
hydrostatic test of all Class 1 subassemblies is mandatory. The following
ASME Code paragraphs were reviewed.
NA-1232 Piping Subassemblies
"Piping subassemblies are defined as sections of a piping system
consisting of fittings and pipes or tubes which are fabricated as sub-
assemblies in a shop or in the field before they are installed in a
nuclear power system..."
NB-6114 Time of Hydrostatic Test of Parts, Piping Subassemblies, and Materials
"(b) The component or appurtenace hydrostatic test when conductv ! in
accordance with the requirements of NB-6221 (a) shall be acceptable
as a test for parts and piping subassemblies."
fib-6221(a) Minimum Required Hydrostatic Test Pressure
"a"
Except as may be otherwise required by material specification
(NB-6114), complete components and appurtenances except those
containing brazed joints, pumps, and valves shall be subjected to
a hydrostatic test at a pressure not less than 1.25 times the
system design pressure prior to installation in the system.
The
system design pressure shall be established in accordance with the
rules of NB-7411.
Further, paragraph (c) of hB-6221 pennits substitution of a system
hydrostatic test for the component hydrostatic test; however, this
substitution rray not be applicable for piping subassemblies.
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Enclosure 8
It is requested that guidance be provided concerning the acceptability of the
perfonnance of hydrostatic testing of piping subassemblies after installattun
into the system by the f abricator.
Secondly, a related question concerns the signing of the Cooe Data Report
(NPP-1 Fonn) and application of the code stamp to the hardware.
(This
question is only applicable if it is permissible to delay the hydrostatic
tests of piping subassenblies until the system hydrostatic test is performed).
During record review of the RCP8 piping it was observed that the hydrostatic
test had not been performed by the pipe manufacturer; however, the code data
report had been signed, with the notation that the hydro had not been
performed; and further, the code stamp had been applied to the hardware.
NA-8231 appears to require the application of a code stamp subsequent to hydro
testing, regardless of whether the test was performed prior to or after
installation of the item. NA-8231 also appears to require a representative of
the manufacturer be present to witness and accept the responsbibility for the
hydrostatic test (of the manufacturer's ar.d ANI item) and to sign the data
report.
It is requested that guidance be provided regarding the signing of code data
reports and application of Code stamp when hydrostatic tests of piping
subassemblies is deferred until the system test by the fabricator.
Guidance is also requested regarding the acceptance criteria and documentation
manufacturer (shop) of the installer (field)ystem hydrostatic test by the
requirements during the performance of the s
.
We appreciate your expeditious review of this matter ano provision of guidance
and inspection program upgrade.
Questions regarding this matter should be directed to myself or D. R. Hunter
(FTS 728-8103) of my staff.
Eric H. Johnson, Director
DRSP, RIV
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Enclosure 9
PEPORANDU11 FOR:
F. J. Miragita, Director
Division of Pressurized Water Reactor Licensing B
FR0M:
Eric H. -Johnson, Director
Division of Reactor Safety and Projects, RIV
SU8 JECT:
CLARIFICATION OF APPLICABLE CODE EDITION AND ADDENDA FOR
REACTOR COOLANT SYSTEM PRESSURE BOUNDARY PIPING AT CPSES
During a routine inspection at CPSES Unit 2 during April - June 1985 (NRC IR
No 50-445/85-07, 50-446/85-05) of the RCS pressure boundary piping, it was
observed that the FSAR comitment was to ASME,Section III,1974 edition
through sumer 1975 addenda; however, the Code Data Report (NPP1) and CMTR for
the piping were to ASME Section II/III 1974 edition through winter 1975
adenda.
This matter was brought to the attention of the applicant and
subsequently the applicant submitted amendment 57 to the FSAR, dated
December 20, 1985, to change the FSAR comitment to 1974 edition through winter
1975 addenda. No basis for the change was available. The reason for this
change is not clear.
It appears, however, that the FSAR was changed to be
consistent with the material certifications as identified during the NRC
inspection.
,
Further 10CFR50.55a, dated February 16, 1974, in effect at the time of
issuance of the construction permit, and 10CFR50.55a. dated January 1,1985,
both require that the reactor pressure boundary piping is required to meet the
code edition and addenda in effect on the date of order of :ne piping. The
purchase orders for Unit 2 RCS piping was dated January 5,1977, and
December 16, 1976, for the "spuncast" piping and manufacture of the piping
subassembly, respectively.
It would appear that code addenda should have been
the winter of 1976, and/or sumer,1976.
Guidance is requested regarding the appropriate code addenda approval for use
at the CPSES site.
Questions regarding this matter should be directed to myself or D. R. Hunter
(FTS 728-8103) of my staff.
Eric H. Johnson, Director
DRSP, RIV
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