ML20149E399
| ML20149E399 | |
| Person / Time | |
|---|---|
| Issue date: | 07/02/1997 |
| From: | Ellershaw L NRC |
| To: | Chamberlain D NRC |
| Shared Package | |
| ML20149E307 | List: |
| References | |
| FOIA-97-177 NUDOCS 9707180185 | |
| Download: ML20149E399 (13) | |
Text
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110;", Dwight D. Chamberlain.-
THRUi 'T,. J E Stetka- .
i
.FROM:
L,.E. Ellershaw'
SUBJECT:
DRS ACTION ITEM 92 CHECK VALVE INSPECTION PROGRAM (TI'2515-110) e p
q DRS. Action Item 92-20. requested the following: (1) Perform a' review of- )
inspection:results from initial inspections. (2) Evaluate TI 2515-110 a
- inspection methodology. (3) Canvas other regions on approach /results to'date~,- .
and (4). Propose alterrate approaches if appropriate. 1
- TI 2515-110 issued November 19, 1991', was intended to provide an evaluation !
of licensee check valve activities:. The inspection elements are based'on-1 regulatory requirements and good practice, and consist of attributes which, if g
.. jimplemented by the licensee in an integrated. programmatic' fashion, should: '
E Cprovide- reasonable assurance of the operability and reliability of check -
valves in safety-related systems. The inspection elements include: testing:- i maintenance (corrective, preventive. and predictive, including non-intrusive testing): corrective action: trending design application review; training.
L and use of industry information. '
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,The following information was. developed during discussions with cognizant
' individuals (lead inspectors and section chiefs) from other regions-and from review of all inspection reports. generated as a result of check valve program
- inspections.
Reaion I ,
a .
Region I performed one. check: valve program inspection-(TMI) during 1992. . The inspection was structured to follow the guidance of the TI: however, the :
o . Region noted that- there was very little. regulatory basis (except in the' areas.
of IST and maintenance) and subsequently determined that their approach should be changed in order to focus more on IST and maintenance activities. '
. The region is currently _ planning on performing one check valve inspection i during the'1993 calendar year, with Calvert Cliffs being the selected' site.
The regi_on is planning on integrating the inspection guidance.of TI 2515-114 (IST) into TI-2515,110. with most of the emphasis being placed on inservice testing of check, valves.
TMI-1 (92-04f !
The licensee *s check.valre.3r.ogram wasia two part program. One part consisted-
=of the-industry initiated cleck valve program and the other part consisted of e the IST program. :It was-'found that neither part was developed as a
^ consolidated'and controlled 1 program document and each 3 art was considered an
~
-unresolved-item pending the. licensee's actions:to estaalish a controlled iprogram documenti In addition; an: unresolved-item was identified regarding .
p the;1ack of any documented: justification for the exclusion of three class
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boundary valves from the IST program. Maintenance program records showed the efforts of a continuing process to improve or maintain good check valve performance, and the use of non-intrusive testing was found to be proactive and effective. Trending was not an extensively used mechanism as evidenced by the issuance of just one trend report pertaining to check valves in the past several years. The corrective action program was considered effective as evidenced by a strong performance in finding problems, considering generic implications, and correcting them. While a design application review was performed, the calculations of valve critical velocity had not received a formal documented review. These calculations were used in determining if a valve required increased testing or preventive maintenance. This was identified as an unresolved item pending the licensee's actions to formally document these calculations. The review of industry information pertaining to 4
check valves was considered to be effectively implemented. The training program was considered to be effective as evidenced by the low rework rates experienced by the plant. All levels of management have been involved with the check valve program. The NRC inspection did not identify any violations or deviations.
Reaion II Region 11 performed one check valve program inspection (North Anna) during 1992. The inspection was structured to follow the guidance of the TI.
The region is currently planning on performing one check valve program inspection during the 1993 calendar year, with St. Lucie being the selected site. It appeared that the region was going to use the same format for the St. Lucie inspection that was used at North Anna.
North Anna 1 and 2 (92-19) i A documented check valve program had been established which was considered to ,
be comprehensive. The IST program for check valves was found to be !
acceptable. While a preventive maintenance program had been established, a '
weakness was identified in that it was found that no formalized method existed to determine which check valves should be placed into the program nor were there documented bases for the valves that were included in the program. Non-intrusive testing methodology had not been established; however, this was i being actively pursued. A corrective action and trending program had been l established and effectively implemented. The design application review was <
considered to be a strength, due to consideration of factors beyond flow, location, and orientation, and there was a continuous upgrade to the check valve program database. The program for handling applicable industry information was functioning in an acceptable manner. The licensee had established a training program, including the development of a " hands-on-lab" for personnel involved in check valves. Licensee self assessment consisted of a cuality assurance inservice ins)ection audit. Strong management involvement anc support was quite evident. T1e NRC inspection did not identify any violations or deviations and it was concluded that the licensee had an acceptable check valve program.
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-Reaion III Four check valve program inspections have been performed: Perry: LaSalle 1 and 2: Kewaunee, and Fermi 2. The inspections at Perry and Fermi were structured _to follow the guidance of TI 2525-110. while the inspections conducted at LaSalle and Kewaunee were an integrated approach using tis (2515-110 and 2515-114 [IST)). It should be noted that the inspection at Fermi did not close out the TI, in that the inspector did not have sufficient time to review all inspection elements.
Region III has committed 1-1/2 FTE to the check valve program effort and it is currently their intent to inspect each of the sites within the region.
Perry (92005fDRSl)
The licensee was in the process of establishing a formal check valve program and an administrative procedure to control the check valve program did not exist. A-formal document did not exist to provide a basis for inclusion or exclusion of safety-related check valves from the IST program. Full flow exercise testing of check valves did not meet the guidance of Generic Letter 89-04. Formal guidance for preventive maintenance of check valves was lacking, even though some of the essential elements of such a guidance were being' executed. Ncn-intrusive testing was not beirig used to verify valve position and only limited use was employed for detecting valve degradation.
There was no formal program to control trending of check valve maintenance, repairs, test results and records from disassembly. The corrective action program appeared to be adequately implemented. The design application review was considered to be comprehensive and provided a rational basis for screening potential problem valves from the total population of check valves analyzed.
Industry information appeared to be evaluated, tracked, and implemented in an adequate manner. The training program was considered to be a strength. There appeared to be a good level of management support. Licensee self assessment consisted of quality assurance audits and surveillances of the IST program and check valves in general. The NRC inspection did not identify any violations of deviations. j Fermi 2 (92014fDRS1)
A check valve program had been developed and was generally considered to be l good. However, there was no administrative procedure controlling the program. 1 The program consisted of two parts: IST and preventive maintenance. Check i valve testing was found to be in accordance with Generic Letter 89-04. The maintenance program was basically preventive, with disassembly and inspection a major element. A non-intrusive testing program had not been established. A )
formal trending program had not been established. The design application l review appeared to be thorough and consistent with EPRI guidelines; however.
in some cases the basis for exclusion of some valves was not clear. i Additionally, it was nut clear 1f valves outside of the systems identified by !
INPO were adecuately reviewed for inclusion into the program. The NRC l inspection dic not identify any violations or deviations.
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-TheLreport stated that'the inspection was not complete and that the TI would remain open pending further inspection effort.
'LaSalle 1 and 2 (92015f0R$1)~
.This inspection, as identified above, was an integration of tis 2515-110 and -114.
The check. valve program was well' established and documented, and consisted of two parts: ~IST and preventive' maintenance. The scope of the program was consistent with INP0's'SOER 86-03. Review of check valve testing procedures and surveillance results indicated that, in general, the testing of. valves was adequate. Preventive. maintenance of check valves was divided into.two parts:
disassembly and inspection; and non-intrusive testing. A significant amount .
of disassembly and inspection was being performed in order to obtain extensive
. base line data. The licensee also performed non-intrusive testing both prior to and after disassembly and inspection in order to help validate the results-of diagnostic testing. This was considered to be a strength. A formal trending program had not been established. Corrective actions appeared to be comprehensive although documentation and classification of identified problems could have been better. The design application review was considered to be comprehensive and included appropriate vendor and industry data. It also !
provided a rational-basis for screening potential problem Valves from the
-total population of check valves analyzed. Strong management support was in evidence. The NRC inspection did not identify any violations of deviations.
Kewaunee (92019fDRSl)
This inspection, as identified above, was an integration of tis 2515-110 l and -114. j i
The check' valve program was generally considered to be good, and consisted of i two parts- IST-and the check valve reliability program (primarily preventive )
maintenance). A review of IST procedures and completed surveillances l indicated that testing methods and frequencies were adequate, and acceptance l criteria were specified. However, it was identified that acceptance criteria for check valve full flow testing had been incorrectly established.
Additionally. the licensee established alert levels and action levels at flow rates less than the required accident flow rates. It was also identified that procedures had not been established to control and document testing of the auxiliary feedwater pump discharge check valves. Apparently, the required reverse flow testing of these check valves was being performed, but only as a result of the testing configuration used for other surveillance requirements.
A non-intrusive testing program had not been established. There was no formal trending of check valve failures . maintenance, or test results. The design application review for valves included in the check valve program appeared to l be rigorous and thorough. However, a formal and documented basis for excluding certain check. valves from the program did not exist. Licensee self assessment consisted of an annual independent technical review which
- documented an' objective evaluation of'the effectiveness of the IST program.
This was considered ~a strength. Management involvement was considered good as illustrated by their commitment to improve the check valve program.
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The NRC inspection did not identify any violations or deviations. The items pertaining to the IST program and design application review were characterized
- as weaknesses and concerns.
Reaion IV Subsequent to the HQ led pilot inspection at Waterford. Region IV performed three check valve inspections at River Bend. Fort Calhoun, and Cooper.
River Bend (92-22)
The check valve program was satisfactory but lacked coordination /information sharing between the IST group and check valve program coordinator. Regarding check valves, the 'iT program was found to be acceptable. Maintenance activities were primarily predictive and were based on a well established non-intrusive testing program. A check valve performance trending program had not been established. A violation was identified for failure to initiate Condition Reports when check valves failed to meet surveillance test acceptance criteria. A check valve design application review was performed, but was limited to valve type and sizing, location, and orientation. A non-cited violation was identified for failure to evaluate vertical orientation of valves, after leak rate failures, in view of the manufacturer's recommendations to mount the valves in a horizontal position. Applicable industry information had been evaluated. incorporated, and well documented.
The NRC inspection identified two violations (one non-cited) and no deviations. l Fort Calhoun (92-25)
The check valve program was sufficient but lacked coordination /information sharing between the program activity and other programs which might affect it.
Regarding check valves, the IST program was found to be acceptable. i Maintenance activities were preventive in nature; however, non-intrusive testing had not been established. A check valve performance trending program had not been established. Problems associated with check valves appeared to .
receive appropriate corrective actions. Several elements of the design I ap)lication review were not in accordance with the guidelines established by EPRI and errors existed between the technical database and the isometric drawings. Applicable industry information had been evaluated and ,
appropriately documented, with generic implications, beyond the specific I details 3 resented. considered. Management involvement in the check valve i program lad been recently increased and there appeared to be a strong i commitment to strengthen the check valve program. The licensee's self assessment activities had identified the lack of formalized coordination between other groups and the check valve program engineer. The NRC inspection i did not. identify any violations or deviations associated with the check valve program.
Cooper (92-23) 1 A formal, documented check valve program had not been established because the !
licensee had considered their past actions on assuring check valve reliability 5 :
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to be adequate. A program was, however, being developed. The IST program, with respect to check valves, was found to be acceptable. Preventive maintenance activities. consisting of disassembly and inspection. had been ,
established and were being imalemented. Non-intrusive testing methodology had i not been established. A checc valve performance trending program had not been i established. The check valve data base was not accurate.-in that the original check valve design review, dated September 1989, had not been updated when subsequent design changes involving check valves were made. The licensee was .
In the process of re-establishing the design review baseline. Applicable !
industry information, including generic implications had been appropriately evaluated and documented. The licensee's self assessment activities identified the need to establish a formal, documented check valve program and to establish a non-intrusive testing program. All levels of management appeared to be cognizant and supportive of these efforts, as evidenced by ac. ions taken. The NRC inspection did not identify any violations or deviations.
Reoion V 1
4 The region had just recently performed a check valve program inspection at 1 4
Palo Verde (92-36); however, the report has not been issued as of this date. )
Discussion with the lead inspector indicated that Palo Verde had an acceptable '
check valve program but it was identified that some valves had not been
, reverse flow tested. The region is planning on performing one check valve ,
inspection during calendar year 1993 at WNP-2. l San Onofre 2 and 3 (92-15)
It appeared that. in general. development of the check valve program was in its early stages even though industry guidance had been available since 1986 and the licensee had direct check valve failure experience since 1985. Review of the valve IST 3rogram revealed the following conditions which were identified as wea(nesses: numerical designations and valve sizes were not consistent between the plant computer data management system and the IST program and an apalicable procedure, and test acceptance criteria established for a number of cleck valves in several safety-related systems did not comply with Position 1 in Generic Letter 89-04. In addition, a non-cited violation was identified regarding approximately 49 check valves in safety-related systems that had not received the required reverse flow testing. There were no administrative procedures addressing check valve maintenance activities and ,
several )oor maintenance 3ractices were identified. A non-intrusive testing '
program lad not been esta)1ished; however, check valve closure was being determined by radiography. There was no documentation of check valve trending I activities. It was concluded that a program for identifying and correcting I check valve deficient conditions existed and was being implemented. The l licensee did not perform a check valve design application review. The review i of certain industry information (Information Notice 88-70) was not adequate as l evidenced by the failure to identify that reverse flow testing of check valves !
was not being performed and the failure to verify that all required valves were in the IST 3rogram. Check valve training activities were largely inadequate, in tlat the only check valve training received by maintenance I personnel since 1985, was a yearly discussion of current industry events. l 1
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4 Senior management involvement in check valve program implementation and assessment was not readily apparent. The NRC inspection identified one non-cited violation and no deviations.
CONCLUSION / RECOMMENDATION Basically, there are 10 inspection elements identified in the TI which, for the most part. have been addressed during the inspections. In general, each region has applied a similar inspection approach. with some elements being weighted more than others. The insaection methodology of TI 2516-110 is rather extensive: however some of t1e elements can be looked at in an integrated fashion. with more effort being focused on IST. maintenance, and design application review. The inspection results revealed a wide range in licensees' responsiveness to establishing check valve reliability programs.
Programs ranged from being virtually nonexistent with little management involvement. to those that were well established and having exceotional management support. It was interesting to note that most of the identified
" hits", in terms of impact. occurred in the area of IST. Considering the extensive amount of industry information including NRC Information Notices and Generic Letter 89-04. and NRR review of licensee programs, it would seem that this area should have had the least problems. It was also noted that only three licensees had established non-intrusive testing programs and just one had implemented trending activities.
In terms of documenting findings. Region IV has identified two violations (one non-cited) and Region V has identified one non-cited violation. For whatever i reasons, other findings appeared to have been violations but were not documented as such.
Regardless, the inspections act as a catalyst for increased licensee actions, and hopefully, improved performance in an area that has experienced continuing problems. It is recommended that Region IV continue this inspection activity at the remaining four sites (Wolf Creek. ANO. Comanche Peak. and South Texas).
Our remaining inspections should be weighted more heavily towards check valve IST. design application reviews, and maintenance activities.
Attached, is a summary table which provides a brief statement describing the status of each of the identified inspection elements, by site.
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Pon M aos eroca huusta INVOICE l
mans cuecas PAvAss.s To Tws u.s. NUCLEAP MGULAtonY comur$5@, WRITI THE emmet 8pfwe4A ON THE CHECK. ANO eiv0C1 Daft
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U.S. PVCLEAR REGULATORY COMMISSION OFFICE OF RESOURCE MANAGEMENT DIVISION OF ACCOUNTINo AND FINANCE October 17, 1986 WASHINGTON, OU 20eN ucamss muusen ta--i i
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Southern California Edison Company ce= Tact:
P.O. Box 800 =Aue ;
2244 Walnut Grove Avenue !
Rosemead, California 91770 m.,,, o ,
Anf.A cooe I NUMeta an I
onca,Tm -3,T Received full payment for EA 86-97, dated September 17, 1986, ;
Docket No. 50-206. $180,000 l
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AMouMT oOE $180,000 rses T i TERMS. h will accrue from the Invosee date et the annual rete of % Payment is due immediatoty. However, interest will be weived if payment le feceived w$ thin E doye from the invoice date.
NOTE.
- If there eso any guestene about the existence or amount of the debt. contact the indudual named abow. For NRC debt collecten procedures s ciudmg internet end pensity prtmeene, see 31 U.S.C. 3717, 4 CFR 101-105, and to CFR 15. The revococon of a license does not waive or effect smv naht than rhm from a heenema ba 9^ rT81970 di *-=% ** ban hv an occhcant or liconene en nov nragenbod faea
' j-/ ' N A 692371 16-66 i,
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i ORGANIZATION:
CRANE CONPANY - CHEMPUMP DIVISION WARRINGTON, PENNSYLVANIA REPORT INSPECTION NO.: 999001048/86-01 INSPECTION DATE: 03/04-05/86 .
]N-SITE HOURS: 20 CORRESPONDENCE ADDRESS: Crane Co.,'Chempump Division ATTN: Richard Carpenter Director of Quality Assurance / Engineering 175 Titus Avenue Warrington, Pennsylvania 18976 ORGANIZATIONAL CONTACT: Mr. Terry Flynn TELEPHONE NUMBER:
(215) 343-6000 NUCLEAR INDUSTRY ACTIVITY:
Manufacture of pumps and valves / spare parts.
I nM ASSIGNED INSPECTOR: _.
Ge J. C. Harper, Rop <ftive Inspection Section (RIS) 5 r!rs ,
Date !
DTHER INSPECTOR (S): J. T. Conway, RIS ~
APPROVED UY: .
f 4 E. W. Merschoff, Chief IS, Vendor Program Branch Date l
INSPECTION BASES AND SCOPE:
A. BASES: 10 CFR Part 21 B. _ SCOPE:
i swing check valve operability at NuclearThe Power Crane Plants.The ins !
Company, Chempump Division was inspected to obtain information reg technical requirements, quality control and other related problems ;
_. associated with the manufacture and maintenance of swing check valves.
PLANT SITE APPLICABILITY:
TVA 1,'2 and 3 (50-259, 50-260 and 50-296) g ,, , ., o - , , 5
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,0RGANIZATION:
CRANE COMPANY'- CHEMPUMP'0IVISION WARRINGTON, PENNSYLVANIA REPORT ~
INSPECTION NO.: 999001048/85-01 RESULTS
) ACE 2 of 5
- A. Violations:
1.
Contrary to Section 21.21 of 10 CFR Part 21, the Crane Co., Chempumpj
._ Division failed to have a procedure for evaluating and reporting defects and nonconformances relating to safety-related ASME Section III components at (valves and pumps) for nuclear service manufactured their facility.
of Defects and Noncompliances on Delivered Components" do describe a method of notifying the Commission of a defect in cases where notification is necessary.
-2.
Division failed to pass down the requirements of 10 C the Abar Corp.
The Abar Corp. supplied the Chempump Division with welding on services October 1982. on diaphragm operated globe control valves, PO 74390 Nuclear Plant, job order number 82PA2-828937.The original order w (86-01-02)
B. Nonconformances:
None.
C. Unresolved Items:
None.
D. Other Findings or Comments:
1.
Crane-Co. Background - Nuclear Valves Prior to 1976,Section III valves were fabricated by the Valve and andCrane The "NPT" Chicagostamps expire plant let their "N" inFittings Division (VFO) o Iowa; Chattanooga, Tennessee; and Indian Orchard, Safety related nuclear valves and Section III spare parts for valves produced at the Chicago facility apparently were not being produced at these an "N" or three "NPT" locations stamp. since none of the facilities ever possessed located in Elmsford . Crane's Director of Engineering for the VFD, New York, indicated that to the best of his knowledge. spare par,ts have not been fabricated by Crane for the pressure retaining compone:nts (i.e., body, bonnet, disc, and bonnet 84 L m
s .
L ORGANIZfTION: CRANE COMPANY - CHEMPUMP D..ISION WARRINGTON, PENNSYLVANIA REPORT INSPECTION NO.- 999001048/86-01 RESULTS: PAGE 3 of 5 fasteners) for nuclear valves fabricated at the Chicago facility.
He also said that the manufacturing and QA records for the Section III valves were probably destroyed.
Crane purchased Flomatics Corporation, a west coast' company, in the
, late sixties and moved the equipment to Warrington, Pennsylvania and started operations as the Chempump Division (CD) in 1971. In the 1973-1974 time frame, CD produced the initial N-stamp valves for the Crystal River facility of Florida Power & Light. CD's Certificate of Authorization (CA) Nos. for the "N" and "NPT" stamps are N-2057 and N-2058, respectively, with an expiration date for both of March 24, 1987. The scope of the two CAs is for the manufacture of Section III pumps, valves, parts and appurtenances, piping subassemblies, and component supports at the Warrington, Pennsylvania facility.
Chempump's product line includes a canned motor pump'made to Section III requirements, a metering pump and the Flomatic valve line plus i converter gear. The percent of nuclear activity relating to the ;
manufacture of spare parts for pumps and valves is approximately 15 percent and 30 percent, respectively.
The CD has never produced a Section III swing-type check valve or associated spare parts for a commercial nuclear power plant. With the exception of four nuclear valves'(globe and angle control) i produced for the Tennessee Valley Authority, the majority of Section i Ill valves and spare parts have been produced for Aerojet Nuclear Company and EG&G-Idaho for the Idaho National Engineering Laboratory (INEL). Approximately eleven swing-type check va7ves were manufac-tured and sent to the INEL between 1975-1978. The valves produced at CD are considered an engineered product line, and distributors are not used to market CD's products. Usually one to three valves are fabricated to a specific design, and they are shipped directly to the customer. In the field, marketing is handled by independent representatives.
l During a review of the Engineering Records for six orders of swing-type heck valves produced for INEL, it was noted that Crane i engineering personnel performed calculations to size the valves l based on the customer's specification requirements referenced in the technical specification. With the exception of feedback from EG&G on the globe valves, CD management was not aware of any contact with other customers regarding failures of swing-type check valves.
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' ORGANIZATION:
CRANE COMPANY - CHEMPUMP DIVIS10N WARRINGTON, PENNSYLVANIA f-REPORT _
No.* 999001048/86-01 INSPECTION RESULTS:
) AGE 4 of 5 A
in Linden, Romeoville, New Illinois. Jersey, and transferred the equ Crane is in the process of renewing the "N" and "NPT" stamps originally held by Aloyco to allow them to continue to manufacture Section III valves and spare parts at the Romeoville facility.
service reconditioning facilities located in Baton R Chicago, Illinois; Houston, Texas; Pittsburgh and Philadelphia, Pennsylvania; Springfield, Los Angeles and San Francisco, California; and Massachussetts.
- 2. Part 21 The CD did to Section 21.6.not have the correct posting of 10 CFR Part 21 accor A Part 21 procedure was posted neither the Part 21 notice nor Section 206 were po(QAP-5), however sted as required.
At the time of the inspection the QA Manager was made aware of the regulations / procedures as stated in Section Part 21.
on Delivered Components" was inadequate.The CD Part address reporting of defects and noncompliances for componentsThe manufactured by the Crane Company, nor does it describe methods of !
I notifying (86-01-01)the NRC when reporting defects and noncompliances. '
It was determined by the NRC inspector that purchase order no dated October 1982 to the Abar Corp. from the CD, did. 74390, not have the !
requirements of 10 CFF, Part 21 as an applicable requirement. The Abar Corporation supplied the CD with body and seat weldments and carbon steel operated globe with stellite control valves.seat rings on 2" - 900 lb, diaphragm TVA, order no. A2-828937, The original order to CD, was from operated globe control valves. Browns Ferry Nuclear Plant, for diaphragm (85-01-02) l-86
j, r
i: '0RGANIZATION: CRANE COMPANY - CHEMPUMP DIVISION 1 WARRINGTON, PENNSYLVANIA REPORT INSPECTION NO.- 999001048/86-01 RESULTS: PAGE 5 of 5 E. Exit Meeting:
Name Tit 1e Company
- 1. Jeff Harper Met'Eng. US NRC
- 2. Thomas Rittenhouse Product Eng. Crane Company '
Chempump Division ,
- 3. Rex Vernon Crane /Flomatic Crane Company Sales Mgr.
- 4. Jim Conway Met Eng. US NRC ,
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