ML20198D523
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{{#Wiki_filter:1. Allegation Category: QA/QC SE, Materials 2. Allegation Number: AQ-53 3. Characterization: It is alleged that Texas Utilities Electric Company (TVEC) failed to maintain traceability on a large motor-operated valve (MOV). 4. Assessment of Safety Significance: Subsequent to making the original allegation, the alleger stated in testimony on March 7, 1984, that the traceability of the valve was, in fact, maintained, that a nameplate was attached, and that the paperwork was completed. Accordingly, the specific valve described by the alleger was not reviewed by the TRT. In order to assess the generic implications of this allegation the NRC Technical Review Team (TRT) reviewed drawings associated with the contain-ment purge systems, the boron injection system, and the containment isola-tion sump outlet, as valves in these areas are similar in type if not size to the valve described by the alleger. The TRT also reviewed the B&R nonconformance log and identified an incident involving a missing code nameplate on a 16-inch Borg Warner MOV as described on nonconformance report (NCR) M-1163. According to the disposition of NCR M-1163, site records enabled traceability of the valve: a replacement code nameplate was furnished by Borg Warner; and the replacement code nameplate was attached to the M0V in the presence of an authorized nuclear inspector (ANI) witness. The TRT verified by inspection that a code nameplate had been attached to the valve (1-HV-4758, in. room 76). The TRT also made a spot check of several similar types of MOVs to verify the attachment of code nameplates on the valves. All of the MOVs checked had code nameplates attached t'o the valves. The ASME Code (1983) also describes acceptable means of verification of items with nameplates removed (in paragraph NCA-8240) as follows: Alternately, if nameplates secured as noted in NCA-8220,are removed from items which have been installed in a nuclear power plant system, the Certificate Holder responsible for completion of the N-5 Data Report shall verify and document that the required nameplate has been attached to the item. Provisions of positive identification and traceability of the items to a specific location and the applicable Data Report shall be included in the Quality Assurance Program or procedure of the Certificate Holder responsible for installation. This alternative shall be reviewed with and found acceptable to the Authorized Inspection Agency (NCA-5121) before being used by the Certificate Holder. Brown & Root (B&R) QA procedure " Identification, Traceability, and Reten-tion of ASME Code Nameplate" (CP-QAP-12.4) also permitted the removal of valve nameplates if a method of material traceability was maintained for such components. Nothing the TRT observed indicated that B&R was not implementing CP-QAP-12.4 or that the program was not in compliance with the ASME Code. gggg g-{~ 0-205 -PIYt FOIA (_9ARDESS-39.. _ P.DR._.._ J
l 5. Conclusion and Staff Positions: Based on a' review of applicable drawings, documentation, and physical inspections, the TRT concludes that the alle-gation that TUEC failed to maintain traceability on large MOVs cannot be substantiated. The alleger's family was contacted on October 23, 1984, and informed the TRT that the alleger wanted no further contact with the TRT; therefore, no exit interview was conducted. - ? ^ 7. Attachments: None. Reference Documents: 1. B&R Procedure CP-QAP-12.4, Rev. 1. 2. B&R Drawing BRP-VA-RB-005. 3. NCR M-2967 Rev. 1. 4. NCR M-1163. 5. March 7, 1984; AQ-53, A-7 Testimony, pp. 16-17. 8. This statement prepared by: houuw. (d d b (,[0[F V. Watson, TRT Date ' Technical Reviewer Reviewed by: -1#20ZF M-7-D H. Livermore, Date Group Leader Approved by: V. Noonan, Date Project Director I 0-206 _}}