ML17252B167
| ML17252B167 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 05/29/1974 |
| From: | James Keppler US Atomic Energy Commission (AEC) |
| To: | Brian Lee Commonwealth Edison Co |
| References | |
| IR 1974004 | |
| Download: ML17252B167 (16) | |
Text
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L .. .9 U. S. ATOMIC ENERGY COMMISSION DIRECTORATE OF REGULA~-0~~--~~E~'!'I_Q~_§_ ~- -------------
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REGION III Report.of Construction Inspection RO Inspection. Report No. 050-249/74-04 Licensee: Commonwealth Edison Company_ Post Office Box 767 Chicago, Illinois 60690 Dresden 3 -License No. DPR-25 Morr*is, Illinois Category: C Type of Licensee: BWR - 809 Hwe Type of Inspection: Announced, In-service Dates of Inspection: April 1, 2 and 23, 1974
- \
Dates of Previous Inspection: March 5 - 8 and 12 - 14, 1974 (Construction)
- ~} [.J. 1D~v-1L-~~-~
Principal Inspector: M. W. Di~kerson S 7{ (Date) {)!/ Accompanying Inspector: I! A. Maura (V.-0. (1_ s=. . ;y?t/ (Date) Other Accompanying Personnel: None Reviewed By: D, W, Hayes, Sett,~ R!~ns~r Reactor Construction Branch 5-°/-7( (Date)
... -...,..... ,---,-- .... - -*--*** -~------~***
SUMMARY
OF FINDINGS
--Ellforcem~ Action A. Violat'ions Certain of the activities at the Dresden 3 plant appear to be in violation of AEC regulations, applicable code requirements and in noncomformance with establiihed procedures, as identified below and are c6nsidered to be of Category II severity.
- 1. Technital Specification Secti6n 6.2. E requires, in part, that:
"All procedures identified in Specification 6. 2 .A (item 7, Surveillance* and testing requirements) and any changes to those procedures shall be reviewed and approved by the operating engineer and the ~echnical staff supervisor in the areas of . . . and the t~chnical staff supervisor in the areas of plant maintenance and plant inspection."
Contrary to the above,' nondestructive examination procedures utilized for the in-service inspection and those for the valve wall thickness measurement program had not beeti reviewed or approved by the operating engineer and technical staff supervisor in the area of plant_maintenance
~nd plant inspection, prior 1o their use. (Paragraph 3 and 6) e: 2. Technical Specification Section 6.2. A "requires, in part, that:
Detailed written procedures including applicable checkoff lists covering items iisted below (item 7, Surveillance and testing requirements) shall be prepared, approved, and adhered to*: 11 Moreover, each of the facility procedures utilized for inservice inspection require conformance to the requirements of AS1:-1E Section XI, including Summer Addenda - 1971, and ASME Section III, Appendix IX, Summer Addenda 1971. 10 CFR Part 50, Appendix B, Criterion IX, requires, in part, that:
Measures shall be established to assure that special processes .
- are controlled and accomplished . . . in accordance with applicable codes, standards, specifications, criteria, and other special requirements."
Contrary to the above, nondestructive examination procedures were being used for the in-service inspection program which did not conform to the requirements of ASME Section XI, including Summer Addenda - 1971, ASl'IE Section III, and Appendix IX, including Summer - 1971 Addenda. (Paragraph 3)
- 3. ASl'1E Section III, Appendix IX, including Summer Addenda - 1971, requires that the basic calibration block material used for ultrasonic exam-anation be of the production material or an equivalent P number grouping.
- 2
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10 CFR Part 50, Appendix B, Criterion VII, requires, in part, that:
* . . "Documentar*y evidence that materials conform to the procurement requirements shall be available at the nuclear J2QWe_r_p_1_~1i_t__.__._ ,_and---------
_________________ -sha-1-1--be-.:...sufficrerrt ~w--rnei.lt.iTJ"l11e--s-pec:ifi~--r~quirements such as codes, standards, or specifications met by the purchased material or equipnent.
Co"ntrary to the above and Technical Specification Section 6.2.A as stated in paragraph A.2 above, the required records were not available to confirm that the calibration blocks, used for in-servi-ce inspection, were of the required materials. (Paragraph 4. c.)
- 4. 10 CFR Part 50, Appendix B, Criterion V, requires, in part, that:
"Activities affecting quality shall be prescribed by documented*
instruction, protedures, or drawings of a type appropriate to the circumstances and shall be accomplished in actordance with these instructions, procedures or drawings. Contrary to the above, and Technical Specification Section 6.2A test records available for review did not substantiate that calibration checks were performed at the frequency required by Commonwealth Edison Compan)~ Procedure No. NDT-C-2. (J?arag;raph 5) . B. Safety Matters No safety matters were identified. Licensee Actior; on Previously Identified Enforcement* Matters Not applicable. Design Changes. Not applicable. Unusual Occurrences. No unusual occurrences were.identified. Other Significant Findings A. Current Findings Not applicable. B. Unresolved Matters
- 1. Tiansfer Mechanisms UT Procedure No. NDT-C-2, No. NDT-C-4, and No. NDT-C-5, as written and approved on April 23, 1974, do not contain provision for transfer mechanisms. The licensee agreed to incorporate a statement in each of the required UT procedures relative to this matter. This matter will be reviewed during a subsequent inspection. (Paragraph 3)
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- 2. Procedure NDT-C-11,. Revision 1, Ul traso11ic Inspection of Flange to Vessel, Flange to -Head Welds, and Flange Ligaments Between~.;---
- -------------- _______ Bolt-llo1.es 1 -Da-~ed-AprH--J:"7-;-:*19T4------ ----
The subject procedure, as written, does not appear to conform to the requirements of ASHE Section III, Appendix IX, relative to a calibration block with the specified size hole for the reference calibration. The licensee indicated a revision to this procedure, already underway, may satisfy this requirement. This matter will be reviewed during a subsequent irispectidn. (Paragraph 3.i)
- 3. Procedure. NDT-C-12, Ultrasonic Inspection of Reactor Vessel Head Welds - Dresden and Quad-C~ties Stations This new procedure is currently under preparation and wtll be rev'iewed during a subsequent inspection. (Paragraph 3. i).
- 4. Documentation for Transdticers Previously, no documentation, relative to the performance of the transducers utilized for the tests, was available for review. This documentation is being procurred by the Commonwealth Edison.Company (CE) and will be reviewed during a subsequent inspection.
(Paragraph 4.d) . . 5~ Validity of Records Test records, which were obtained during this outage by use of procedures which were considered in no.nconformance with the ASME codes, are considered unacceptable until they have been reviewed and justified by CE. ~his review and justification will be examined during a subsequent inspection. This justification may also be presented by CE as evidence that the procedures utilized were equivalent, or superior, to those ~pecifi~d in ASHE Section III, Appendix IX. This equivalency justification, i f submitted, will also be* reviewed for a~ceptability. (Paragraph 5)
- 6. Technical Justification for Thin Wall V~lves A total of eight valves were measured and established to have wall areas below the specified wall .thickness required. Five were inciuded in the original selection of 26 valves to be measured, and the remainder (three from the same subset) were measured as a result of finding wall thicknesses below specified requirements on the originally ..
selected valves. CE intends to provide technical justificatiol:i. f6r acceptance of these valves as is *. This ju~tification will be reviewed during a subsequent inspection. (Paragraph 6)
)
C. Status of Previously Unresolved Matters
- - --------*- - --------Not--apprtcaole. ____ - - -- - -- -----
Management Interview_ A. The following persons attended the management interview at the conclusion of the inspection. Commonwealth Edison Company*(cE) B. B. Stephenson, Station Superin~endent
*. A. M. Roberts, Assistant Superintendent R. L. Williams, Technic?l Staff Engineer E. E. Potter; Senior Engineer - Operational Analysis Department E. (NMI) Budzechowski, Quality Assurance Engineer
- Part Time B. Matters discussed and comments, on the part of management personnel, were as follows:
- 1. The inspector discussed the apparent violation of Technical Specification 6.2.E. None of the procedures examined on April 1, 1974, and being utilized for either the in-service* inspection or the valve wall thick-ness measurement pr_ogram had been approved, as required, by the operating engineer and technical.staff supervisor in the areas of plant maintenance an<l plant inspection.* The licensee indicated that subsequent revisions to the .procedur.es had received the appropriate approval.
- 2. The inspector stated that a review of certain procedures, in use for the in-service inspection on April 1- and 2, 1974, indicated that they were not in conformance with the requirements as specified in ASME Section III, including Summer -.;L971 Addenda; ASHE Section III, Appendix IX, including Summer - 1971 Addenda; and ASME Section XI, including Summer - 1971 Addenda, and that this appeared to be a violation of 10 CFR Part 50, Appendix B, Criterion IX. The inspector acknowledged that revision to the procedures had, in most cases, satisfied this requirement. However, one procedure, No. NDT-C-11, as presently approved,.still did n6t appear to meet the requireme~ts but that a new revision, presently underway, may provide for this requirement. Additionally, procedures No. NDT-C-2, No. NDT-C-4 and No. NDT-C-5 did not provide for transfer mechanisms. The licensee indicated a*revision to these procedures for transfer mechanism was in progress. The inspector stated that the revisions to procedures No. NDT-C-11, No. NDT-C-2, No .. NDT-C-4 and No. NDT-C-5 would be reviewed during a subsequent inspection.
- I:::.~ .. .:.~;
.9.
- 3. The inspector stated that documentation to certify that the calibration
_____ ----~--b_l_gck_s_w_er_e _oLan -equ-i-va-1-en-t:--P-number-group'ing, as-fequlrea 'GyASl*lE_______ -- Section III, Appendix IX, was not available for review prior to the start of work and tl~t this appeared to be a violation of 10 CFR Part 50, Appendix B, Criterion VII. The inspector acknowledged that the certifications had now been provided.
- 4. The inspector !3 tated, *contrary to the requirements that calibration checks be mad<.:. every four bouts, the test data (for March 29, 1974) indicated that Lliis had not been done and that this was in non-conformance with Procedure No. f..'DT-C-2, Revision 2, dated December 3 ,. 1972 and was an apparent violation of 10 CFR Part 50, Appendix B, Criterion V.
- 5. The inspector discussed the status of documentation relative to the performance of transducers and_ indicated tha.t tbis matter would be
-reviewed during a subsequent inspection.
- 6. The inspector indicated that test records for the in-service inspection work, performed according to procedures not in conformance with ASHE requirements, may not be acceptable. The licensee acknowledged this and indicated they would perform a review of this data and provide justification for data which.they consider acceptable. The inspector indicated that this information would be reviewed by the inspector dur~1g a subsequent inspection.
- 7. The inspector duscussed the results of the valve wall verification pr_ogram regarding the eight valves which had been found to have-wall areas below the specified minimum thickness. The inspector added that it was his understanding that the use of these valves, as it, would be justified . . The inspector also indicated that this justification, to be submitted in accordance with the RO:III letter to (~E dated June 29, 1972, would be reviewed by RO: III.
REPORT DETAILS ----- - - - - - - - - - - - - - - - - -- - -- - - - - - - - - - - - - - ----- - - - ---------------- -~--- - -- -- - - - - - - ----------- --- Persons Contacted The following persons, in addition to individuals listed under the Management Interview Section of this report, were contacted during the in~pection. Commonwealth Edison Company (CE) W. L. Stiede, System Operational Analysis Engineer - Operations Analysis Department R. L. Dlesk, Section Engineer - Operations Analysis Department W. *w. Witt, Engineering Associate - Operations Analysis Department T. E. Watts, Technical Staff Supervisor Results of Inspection
- 1. Review of Dresden 3 Technical Specification*(TS) Requirements - Table 4.6.1 The TS Table 4.6.1 established the exa~ination areas, categories, examina-tion methods, inspection interval, and extent of examination. The e~arnina tion methods and that portion of the.required ten-year examination program, to be accomplished during this reactor outage, appear to meet the require-ments of ASHE Section XI.*
- 2. Qualification of NDE .Personnel Review of test contractor's (Feabody Testing, Incorporated) petsonnel qualification records indicated conformance *with the requirements of SNT-TC-lA, as applicable.
- 3. Examination Techniques and Procedures All nondestructive examination procedures for in-service inspection were provided by CE and had been certified by a represeptativg of the Operations Analysis Department to be in conformance with referenced ASHE codes.
Additionally, a representative of the licensee stated that the code inspector had verbally approved the procedures and that verbal approval was to be followed by written approval. Review of the NDE procedures by the inspector established that: (1) the procedures had not been approved in accordance with the requirements of Section 6.2.E of the technical specification, and (2) volumetric examina-tion Procedures No .. NDT-C-1, Revision 0, Ultrasonic Inspection of Pressure* I .. Retaining Bolting Two Inches in Di.ameter and Above, dated January 4, 1974; No. NDT-C-2, Revision 2, Ultrasonic Inspection of Pipe Welds, dated Decemb_~_!: __ .1,_J..9.21;. No_.* __ ND-T-=C=t1.,-Rev-ision--8-,.-Ui:tra-sorrrc* Tns-pecEro11*0y*--------.-
- -Exte-~al Support Attachments Welds on Piping, dated January 7, 1974; No. NDT-C-5, Revision 0, Ultrasonic Inspection of Reactor Vessel Welds -
Dresden and Quad-Cities Stations, dated January 4, 1974; and No. NDT-C-11, Revision 0, Ultrasonic Inspection of Flange to Vessel, Flange to Head Welds, and Flange Ligaments Between Bolt Holes, dated March 1, 1974, did not appear to conform to the requirements of ASHE Section III, including Summer - 1971 Addenda, Appendix IX, of Section III, including Summer - 1971 Addenda, and Section XI, including Summer - 1971 Addenda.
/
Relative. to review and approval of the procedures, Section 6.2.E of the technical specification requires that all procedures identified i.n Technical Specification No. 6.2.A (item 7, Surveillance and testing require-ments) and any changes to those procedures be reviewed and approved by the operating engineer and the technical staff supervisor in the areas of plant maintenance and plant inspection. Since none of the procedures had received this review and approval at the time of the initial inspection. (April 1 and 2, 1974) and they were observed to be in use, the licensee was informed that this was a violation of the technical specifications. Results bf the review, conducted on April 1 and 2, 1974, for each of the procedures, was as follows:
- a. NDT-C-1,. Revision O, Ultrasonic- 111.spection of. Pre_ssure Retaining Bolting Two Inches in *niameter and Above, Dated January 4, 19714 The procedure did not provide (for bolts over four inches in diameter) for the calibration of equipment in accordance with ASHE. Sec:tion III, through Sununer Addenda - 1971, Article NB-2585. 3. Article NB~2585.3 requires that calibration be established on a test bar of the same nomine.l composition and diameter as the production part and of one-half the length, utilizing the code.specified drilled hole. Instead, the procedure utilized the back reflection from the opposite end of the bolt.
- b. NDT-c...,2, Revision 2, Ultrasonic Inspection of Pi.pe Welds, Dated December 3, 1973 The procedure utilized: Cl) pieces of pipe (for piping up to ten inches outside diameter) (2) a section of pipe (for piping ten inches to twenty inches outside diameter) and (3) a flat plate calibratfon piece (for pipe over twenty-inches in diameter) each with notches nominally 3% to 10% of wall thickness machined in the outside diameter and the inside diameter surfaces in lieu of the drilled holes, as required by ASHE Appendix IX, Section III, with Addenda through Summer - 1971.
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The code allows, under Article IX-3434, other calibration reflectors, provideE_egui\'.__a_l~nt x~s_p_gns_e _is__demo_nstrated *- -Howev.er:-,--the-1-icensee---
--- ----- ------w-asUilab1e to conclusively demonstrate this equi\ralency. lvloreover, the procedur~ did not provide for transfer mechanisms, as required by Appendix IX of Section III.
- c. NDT-C-4, Revision 0,- Ultrasonic Inspectionof External SuE_port Attachment Welds on Piping, Dated January 7, 1-974 The comments for Procedure No. NDT-C-2, above, also apply No.
NDT-C-4.
- d. NDT-C-5, Revision o, Ultrasonic Inspection of Reactor Vessel Welds Dresden and Qu~d-Cities Stations, Dated January 4, 1974 The procedure for calibration, relative to longitudin.11 waves, utiliz'ed the back of the calibratiOn block as the primary reference in lieu of the basic calibration hole as required byArticle IX-3433 of Section III, including Summer Addenda - 1971. Moreover, the procedure did not provide for. transfer mechanisms as required by Appendix IX of Section III..
- e. NDT-C-10, Revision 0, -Ultrasonic Inspection of Inner Radius of Nozzle-to-Vessel Junctio'n, Dated Narch 1, 1974 The procedure provides for change of the standard wedge used during calibration to a compound angle wedge appropriate to the nozzle being examined during the examinai:1on. This practice, while apparently not excluded by the code, did raise questions as to the validity of the test.
- f. NDT-C-11, Revision 0, -Ultrasonic Inspecti6n of F~ange-to Vessel~
Flange-to Head Welds, and* Flange Liga1nents Between Bolt Holes~ Dated March 1, 1974 The procedure did not specify a reference reflector, and it could not be determined' i f the procedure was in accordance with the code requirements. These matters (items 3a-f above) were discussed with members of the 'CE Operations Analysis Department on April 5, 1974, and on April 8, 1974, at the RO: III offices. A member of the Dresden Technical Staff also attended the discussion on April 8, 1974. At these meetings, it was concluded that CE would either provide procedures complying with the ASME requirements or would provide conclusive evidence of equivalence, or superiority, as allowed by ASHE Section III, for the methods used.
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; g. NDT-V-1, Revision 0, -Visual- Examination *of Nuclear Reactor Coolant
- -*- ~--------*---- ______S)~-t~m-~_QJllR.QJL~n..t.s_,_Dat.ed_No.v.ember- 10.,.. 197-3----- ---*------- -- - - - - - -
This procedure was determined to be acceptable, except for the required approval as stated previously.
- b. NDT-D-2, Revision 1, Procedure for Nonaqueous Red Dye Liquid Examination, Dated November 3, 1973 The procedure was determined to be acceptable, except for the required approval as stated previously.
L Revised Procedures A review of the revised and/or new procedures, conducted on April 23, 1974, established that all procedures had been appropriately approved by the technical staff and that Procedures No. NDT-C-1, No. NDT-C-2, No. NDT-C-4, No. NDT-C-5, No. NDT-C-10 and No. 1'i1JT-C-14 (new procedure) had been revised to conform with ASHE requirements; with the exception of provisions for transfer mechanisms in.Procedures No. NDT-C-2, No. NDT-C-4 and No. N-UT-C-5.. The licensee agreed to revise these procedures to conform to _the transfer mechanisms requirement,* Additionally, the code inspector had not approved the new revised procedures, but was.expected to do so. These matters will be reviewed during a e: subsequent inspection. A review o.f revised Procedure No. NDT-C-11 established that it still did not conform to the ASHE requirements relative to calibration standards, since the procedure did not provide for calibration utilizing a reference.hole. This matter was discussed with the licensee, and the inspector was .. informed that this procedure was presently under.revision and may alleviate this problem. Additionally, a new procedure for UT inspection of reactor vessel head welds, No. NDT-C-12, is under preparation. These procedures will be reviewed during a subsequent inspection. Regarding the matter of calibration equivalency or superiority, the licensee was not able (during the April 5 and April 8, 1974 discussions) to demonstrate, conclusively, that the procedures utilized were equivalent or superior to those defined in ASME Section III and Appendix IX. However, the licensee may still submit additional. information on this matter at a later date. The new procedures, revie"ived on April 23, 197 4, were as follows: (1) NDT-C-1, Revision 1, Ultrasonic Inspection of Pressure Retaining Bolting Two Inches to Four Inches in Diameter, Inclusive, dated April 10, 1974.
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(2) NDT-C-2, Revision 3, Ultrasonic Inspection of Pipe Welds, Dresden Station, Units 1, 2 and 3, and Quad-Cities St_ation,_ -*-- -~- - - --~- ---- ---- --*- ----urrtn; *1--ana ;--dateCl-April 1.'.r;-*19-74:- ------ --.-- -- - -- (3) NDT-C-4, Revision 1, Ultrasonic Inspection of External Support Attachment Welds on Piping, Dresden Station, Units 1, 2 and 3, and Quad-:-Cities Station, Units l* and 2, dated April -16, 1974. (4) NDT-C-5, Revision 1, Ultrasonic Inspection of Reactor Vessel Welds, Dresden and Quad-Cities Stations, dated April 10, 1974. (5) NDT-C-10, Revision 1, Ultrasonic Inspection of Inner Radius of Nozzle-to-Vessel Junction, dated April 18, 1974 (including justification for the use of a contoured shoe). (6) J\TDT-C-11, Revision 1, Ultrasonic Inspectiol'.- of Flange-to-Vessel, Flange-to-Head Welds, and Flange Ligaments Between Bolt Holes, dated April 17, 1974. (7) NDT-C-14, Revision 0, Ultrasonic Inspection of Pressure Retaining Bolting Over Four Inches in Diameter, dated April 13, 1974.
- 4. Certifications
- a. Certification for the liquid penetrant materials was established as acceptable.
- b. The certifications for ultrasonic test couplant (glycerine) dated September 5, 1973, was considered unacceptable during the inspection on April 1, 1974, since it did not specify the halogen content of the glycerine. A certification, provided during the inspection of April 23, 1974, was considered acceptable. In the interim period, a certified alternate couplant, exosen.i4, had been utilized.
- c. Material certifications for the ultrasonic test calibration blocks were not available for review during the inspection on April 1 and 2, 1974, and the licensee was= informed .that this was a violation of 10 CFR Part 50, Appendix B, Criterion VII; since documen.tation which would establish that the blocks are of the proper P*group, as required by Appendix IX of ASME Section IIT, was not available for review.
During the inspection of April 23, 1974, acceptable certification dated April 19, 1974, for all of the calibr;:1tion blocks, *"ms reviewed by the inspector.
- d. No documentation was provided for the inspector's review which would attest to the performance characteristic of each transducer utilized for-the in-service inspection. However, this documentation is being procured by CE and will be reviewed during a subsequent inspection.
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- 5. Test Records The inspector reviewed reports of test results and found that requirements for documentation of the examinations had been met. However, the v~lidity of tJ:iese records, in view of the apparent noncomformance of the UT procedures with the ASHE requirements, are questionable and remain to be established by CE. This matter.was discussed with the licensee, and he is presently in the process of establishing validity. The validity of these records, if accepted by CE, will be reviewed during a subsequent inspection. In addition, the review established that an apparent violation of Procedure No. NDT-C-2, Revision 2, Ultrasonic Inspection of Pipe Welds, dated December 3, 1972, had occurred on March 29, 1974. Calibration checks had not been recorded as being made every four hours as required by che procedure. The.licensee was informed that his was a violation of 10 CFR Part 50, Appendix B, Criterion V.
- 6. Valve Wall Thickness Verification Program The inspector reviewed the test contractor's (Nuclear Services Corporation) examination techniques, certification of equipment, material and personnel, and procedures relative to the valve wall thickness verification program and established that they were acceptable, except for the required revie~v.
and approval of the procedures by the operating engineer 'and the technical staff supervisor in the area of plant maintenance and plant inspection. Additionally, certific.ation of .the transducers used was not provided (certi.fication for the *transducers was reviewed and found acceptable on April 23, 1974).. The licensee's letters to RO:III of August 3, 1973, and August 30, 1973, stated the number of valves to be measured for adequate wall thickness were to be randomly selected from subsets comprised of the total number of similar valves from the Dresden Station, Units 2 and 3, and Quad-Cities Station, Units 1 and 2. During this inspection, the licensee's representative indicated that the random sampling system utilized had resulted in the select1on of 26 valves from Dresden 3 to be measured during this outage. The procedure (No. NUT-NC-2, Revision 4) utilized for verifying valve wall thickness, was developed by Nuclear Services Corporation and provides for comprehensive calibration of the UT instrumentation utilizing calibration blocks of the appropriate material. The grid pattern for measurements was as follows:
- a. For valves under six inches, a nominal two-inch grid patteru.
- b. For valves six through 16 inches, a nominal three-inch grid pattern.
- c. For valves 16 inch*and greater, a nominal six-inch grid pattern.
For valves 3/4 to 6 inches in size, a minimum of twelve thickness readings, ____________ lo_c_a_t_ed__ for___rnaximurn_ co.:verage _o_r__ as_ limited __b~--the '\Tab1-e -configuation_, __ wil.J-~- be taken. A revjew of the data established that, of the 26 valves initially selected for measurement, five had meastirernents which were below the specified minimum wall thickness. The valves are identified as No. 1501-25A, 16" stainless steel check valve; No. 220-57B, 18 11 carbon steel ga.te vslve; No. 202-4A, 28 11 stainless steel gate valve; No. 1001-SB, 14" stainless steel gate valve; and No. 1001-2C, 14 11 carbon steel gate val~e. Additional valves, No. *1001-2A, 14 11 carbon steel gate valve, No. 202-4B, 28 11 stain-less steel gate valve (bonnet only), No. 202-SA, 28' 1 stainless steel gate valve (bonnet only), No. 202-SB, 28" stainless steel gate valve (bonnet only), and No. 1501-25B, 16 11 stainless steel check valve *were measured, when initially measured valves in each of their respective subgroups were found to. be below the specified minimum wall thickness by more that 2%, i.e., the specified acc~racy of the rn~asuring equipment. Measurements on the bonnets of Valves-No. 202-4A (11 measurements), No. 202-4B (_3 uieasurements), and* No. 202-SB (_l measurement) ~.:rere found to be below- the specified minimum of- 2. 37 5 inches (as~uming an additional 2% .for accuracy of the equipment). . Those on valve No. 202-SA were within the specified accuracy. Some measurements on valve No. 1501-25A, while below the originally specified minimum of 1 9/16 inches, are not considered by CE to be below the required minimum for this valve. The specified thicl:-.ness was apparently incorrect and should have been 1. 077 inches. This is also true for valve No. 1501-25B -(measured as an additional valve). The correct wall thickness requirement will. be documented by CE. The specified minimum.for valve No.*.220-57B is 1.75 inches, and one measurement on the body.at grid location'D-'-10 read 1.72 inches (judged by CE to be within the 2% instrumentation accuracy). The specified minimum* for valve No. 1001.,-SB is L 3/8 inches, *and one measurement on the neck of the valve at grid location B-7 read 1.35 inches (judged b.y CE to be within. the z'% instrumentation accuracy). The specified minimum thickness for valve No.,1001-ZC is 1 3/8 inches, and two measurements on the body at_ grid locations D-7 and D-8 read
- 1. 37 and 1.18 inches, resp_ectively. The former was judged by CE to be within the accuracy of the instrumentation, while the latter is considered below the required minimum. Two other valves in this subgroup were also measured. Valve No. 1001-2B was measured as meeting the minimum require-ments during the normal program.(part of the originally selected 26 valves). Valve No. 1001-2A was measured, as noted previously, and found to be acceptable.
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Discussion with a *representative of the licensee on these matters indicated ____ _:___ ___ ---*- _______ tJ1a_t_jl!~ti):ic_cit_ion fPL_a_ccep_t_an._c__g__ of_ _th...e. Y:.al_y_e_s_, _as__i_s_ ,_iu_ac_co_rda_11-~~---- with the RO: III letter to CE relative to v*alve wall measurement, dated June 29, 1972, will be.provided (including those accepted, based on the 2% instrumentation accuracy) for each of the valves measqred to be below the s.pecified minimum (or originally specified minimum). This matte~ will be reviewed during a subsequent inspection.
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