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) | |
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MEMO TO: George Mulley _
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FROM:
SUBJECT:
Sworn Statement of Ian Barnes, dated July 25, 1986 After reading Mr. Barnes' testimony, I feel compelled to respond in defensetheofASME understand the statements code, that I erred, that I did not 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 fabricators, 1 onengineers architect pages 11-33, Mr. Barnes alludes to pipe 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 CVCS with fabricated from bulk field welds numbers material and installed in the 1 and.3, reviewed during the inspection were summarized.and then certain records Inspection of this spool piece was not by chance.'
was 50051,planned 50053,to inspect the RCPB system and records to IE ModulesAn inspection and 50055. I choose the subject spool piece to verify compliance requirements with the ASME Code and other regulatory 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 mark I attempted, along with a site engineer, to to verify the a markings which could be used to trace the material markings. ppropriate documentation, but could find no Approximately two months such or of later, at the, r6 quest 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 identification I considered originally the issue of whether I had missed the or whether the inspection a no-win. issue. it was placed there af ter The next item 'I testimony covered would on pages like15-24.
to discuss relates to Mr. Barnes' hydro testing ';f a RCPB piping subassembly This is the issue concerning Leg). The inspection report (446-8505) addressing (Loop 3RC Cold stated the following ASME Code Sections: the issue 1.
NB-6114(a)that piping subassemblies, states in respect to the time of testing the component test, >
in accordance with the requirements of NB-6221(a)whenshall acceptable as a test for piping subassemblies.
conducted be i i
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8708200089 870312 PDR ADOCK 05000445 0 PDR I >
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- 2. NB-6221(a) states that_ completed components shall --
be the subjected system. to a hydrostatic t e~s t prior to installation _
in 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 to NB-6221 or to NB-6221 (a) through NB-6221(a) only, (c). It, therefore, not appears to installation.
that the subassembly should have been tested prior -
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The is ASME Code is a very difficult document to understand and subject to O
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 draft inspection report to accept this decision as reflected in the 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 time (12-18-86),
was apparently supported by RIV management. At this 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
' chat questions only field relating to the testing procedures, I was concerned 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 Personnel field of over 50 concurring years, concurred with the draft report.
were:
Ins or -
truction, Shannon Phillips, Senior Resident Doyal Hunnicutt, Section an Chief ove Branch Chief. Apparently this was later nt ice of Mr. Barnes. .
In summary, NRC and Ihave believealways in consistent enfor/ cement throughout chain-of-command, attempted, through regional to get questionable issues resolved. It is an are they injustice in error, to inspectors for statements to be made that don't know the code, need training, etc.,
just because they can't agree withadditional the one person in the region who has been labeled " Code-Expert".
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