ML20237L125
| ML20237L125 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/18/1986 |
| From: | NRC |
| To: | Mulley G NRC |
| Shared Package | |
| ML20237K807 | List:
|
| References | |
| NUDOCS 8708200089 | |
| Download: ML20237L125 (2) | |
Text
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4, *.: '
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MEMO TO:
George Mulley
~
FROM:
SUBJECT:
Sworn Statement of Ian Barnes, dated July 25, 1986 After reading Mr. Barnes' testimony, I feel compelled to respond in defense of the statements that I erred, that I did not understand the ASME code, and that I did not seem to want to grasp what Mr. Barnes was telling me; and secondly, I would like to attempt to clarify at least two issues which were obviously misunderstood by Mr. Barnes.
In testimony concerning marking of a particular spool piece, wh.ich is coverer 1 on pages 11-33, Mr. Barnes alludes to pipe fabricators, architect engineers purchasers, etc.,
indicating that the subject spool piece was a, purchased part.
The ori;inal draft of the inspection report stated that the spool piece was field fabricated from bulk material and installed in the CVCS with field welds numbers 1 and.3, reviewed during the inspection were summarized.and then certain records Inspection of this spool piece was not by chance.'
was planned to inspect the RCPB system and records to IE ModulesAn inspection
- 50051, 50053, and 50055.
I choose the subject spool piece to verify compliance with the ASME Code and other regulatory requirements for site fabricated parts.
I concluded that the site contractor was then placed in the role of supplying material and must mark material for traceability when it was During the inspection, separated from the bulk material which should have been mar I attempted, along with a site engineer, to verify markings which could be used to trace the material to the a
markings. ppropriate documentation, but could find no such or Approximately two months
- later, at the, r6 quest of HRC management, I
accompanied another site engineer to the part and an identification w, a pointed out to me.
Since the report had not been issued, I a91ced to drop the findings because I considered the issue of whether I had missed the identification originally or whether it was placed there af ter the inspection a no-win. issue.
The next item 'I would like to discuss relates to Mr. Barnes' testimony covered on pages 15-24.
This is the issue concerning hydro testing
';f a RCPB piping subassembly (Loop 3RC Cold Leg).
The inspection report (446-8505) addressing the issue stated the following ASME Code Sections:
1.
NB-6114(a) states in respect to the time of testing piping subassemblies, that the component test, in accordance with the requirements of NB-6221(a)when conducted shall be acceptable as a test for piping subassemblies.
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I 2.
NB-6221(a) states that_ completed components shall be subjected to a hydrostatic t e~s t prior to installation in the system.
It is my position that all of NB-6221 (i.e.
sub paragraphs (b) and (c)) do not apply to piping subassemblies since sub-paragraph 6114(a) makes reference to NB-6221(a)
- only, not to NB-6221 or to NB-6221 (a) through (c).
It, therefore, appears that the subassembly should have been tested prior to installation.
~.
The ASME Code is a very difficult document to understand and O
is subject to interpretation in many instances.
Since we were not in agreement on the hydro testing issue in RIV, I considered this to be an area where an official NRC position (in writing) was needed in order to ensure that RIV took a regulatory position consistent with other regions.
I was quite willing to accept this decision as reflected in the draft inspection report by leaving the issue unresolved.
This was not permitted, however, since as stated in Mr. Barnes' testimony, he saw no need to go to NRC Headquarters, and his position was apparently supported by RIV management.
At this time (12-18-86), I still do not know the official position of the NRC in respect to the time of hydro testing of piping subassemblies.
Another part of the above issue which was covered in the draft inspection report, related to the hydro test which had been done after the piping subassembly was in place.
Because of inadequate documentation of the hydro test and responses to my questions relating to the testing procedures, I was concerned
' chat only field welds had been adequately observed during the test and that possible weak points in shop welds and base metal repairs could go undetected.
This was left unresolved in the draft.
I am not sure about the final report.
I would also like to point out that at least three NRC management personnel, who had accumulated experience in the nuclear field of over 50 years, concurred with the draft report.
Personnel concurring were:
Shannon Phillips, Senior Resident Ins or
- truction, Doyal Hunnicutt, Section Chief an Branch Chief.
Apparently this was later ove nt ice of Mr.
Barnes.
In summary, I believe in consistent enfor/ cement throughout NRC and have always attempted, through regional chain-of-command, to get questionable issues resolved.
It is an injustice to inspectors for statements to be made that they are in
- error, don't know the
- code, need additional
- training, etc.,
just because they can't agree with the one person in the region who has been labeled " Code-Expert".
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D1 7d e
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