ML20209E578

Rev 1 to Isap VII.b.2, Valve Disassembly, Results Rept

ML20209E578
Person / Time
Site:	Comanche Peak
Issue date:	03/20/1986
From:	Beck J, Hansel J TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
Shared Package
ML20209E569	List: ML20209E565 ML20209E578
References
FOIA-86-272, FOIA-86-454 VII.B.2, NUDOCS 8609110230
Download: ML20209E578 (86)

Text

{{#Wiki_filter:r ,f e. ~ y /p-rp COP.ANCHE PEAR RESPONSE TEA". REST!LTS REPORT ISAP: VII.b.2

Title:

Valve Disassembly REVISION 1 3 /R % Issue Coordinator Defe / QY 3 fl8' *&L Revf Team Leader Datl (& &). /$L 3/.zo /P 6 Johp. Beck,ChairmanCPRT-SRT Date 8609110230 860904 PDR FOIA GARDE 86-272 PDR g,/ q

v. }., Revision: 1 'Page 1 of 20 RESUI.TS REPORT ISAP V11.b.2 Valve Disassembly 1.0 DEST'ElPTIUS 01 ISSUE (USSRC Letter of January 8, 1985, l'a rx 23) "The TRT found that installation of certain butt-welded valves three systems required removal of the valve bonnets and internals in prior to velding to protect temperature-sensitive parts. The three systems involved were the spent fuel cooling and cleaning system, the boron recycle system, and the chemien1 and volume control This installation process was poorly controlled in that system. disassembled parts were piled in uncontrolled areas, resulting in lost, damaged, or interchanged parts. This practice created the potential for interchanging valve bonnets and internal parts having different pressure and temperature ratings." 2.0 ACTION IDENTIFIED Evaluate the TRT findiny,e and consider the implications of these !indiny,s on construction quality. ".. examination of the pu ent tal saiety implications should include, but not be limited te the areas or activities selected by the TRT." "Addre== the root cauce of each finding and its generic implications..." " Address the collective significance of these deficiencies..." " Propose an action plan...that will ensure that occur in the future." such problems do not 3.0 EACKGROUND The valves identified by the NRC staf f are of a particular type which required disassembly for installation. Other possible reasons for valve disassembly include hydroter,t, flushing, purging, and repair, and therefore many different valve types could be affected if the concern is substantiated. 1 Accordingly, all valves l which had been disassembled under the Construction QA program, regardless of valve type or reason for disassembly, were included in this action plan. The loss of or damage to valve parts is not a concern if the parts are replaced with acceptable spare parts and properly documented. The program for valve testing provides assurance that valve damage that would hinder proper operation of the valve is detected and corrected. As the issue as stated in SER-ll did not allege any

f'j) Revision: I Page 2 of 20 RESULTS REPORT ISAp V11.b.2 (Cont'd)

3.0 BACKGROUND

(Cont'd) improper handling of lost or damaged valve parts this action plan focused on the " potential for interchanging valve bonnets and internal parts having different pressure and temperature ratings". SER-11 states in part that: "The TRT interviewed QC inspectors who knew of recent incidents involving lost, misplaced or interchanged valve bonnets. The QC inspectors stated that when these valves were disassembled for system flush under the direction of startup test engineers, one bonnet was lost and a mismatch between valve body and bonnet occurred. Although these incidents were documented in nonconformance reports, see e.g., NCR M-Il645 (May 8. 1984), the prob 1ces associated with maintaining control of valve parts during installation, system flush, and startup indicated to the TRT that in spite of the issuance of the revised traveler and CP-CPM-9.18 in Juno 19E3, loss, damage, and interchange of valve parts continued to occur. The TRT did not find any evidence that B6R addressed the problem on a programmatic basis, e.g., by use of a forr.a1 corrective ection request (CAR)... The TRT concludes that the allegation concerning interchanged valve parts (AQ-52) was substantiated. The TRT also concludes that this condition has potential quality significance due to the generic implications. The generic implications are based on documented evidence that the interchange of valve parts did occur and effective programmatic corrective action was not implemented to identify the problem and to prevent the loss, damage, and interchange-of valve parts." An assessment of TUGCO's handling of programmatic corrective action will be included in ISAP VII.a.2, "Nonconformance and Corrective Action Systems". This action plan (Valve Disassembly) was structured to evaluate the adequacy of current procedures to control the valve disassembly / reassembly process and to evaluate the physical status of valves which are installed in the plant and have been disassembled and reassembled. i

d ^ Revision: 1 Page 3 of 20 RESULTS REPORT ISAP VII,b.2 (Cont'd) 4.0 CPRT ACTION PLAN 4.1 Scope and Methodology The objective of this action plan was two fold:

1) to evaluate if procedures are adequate to control the valve disassembly / reassembly process; 2) to evaluate if valves that required disassembly were properly reassembled and, if not, whether an improperly reassembled valve could result

~ in a code violation or have a safety consequence. The following tasks were implemented to achieve these objectives: - Identification of all valves which have been disassembled and reassembled under the Construction QA program. - is procedure review to determine adequacy of control of valve components during disassembly and reassembly. - A safety consequence analysis to determine if valve component parts from one valve are physically capable of fitting up to another valve of the same type but having a lower pressure / temperature rating or Code class and identification of potential risks if such reassembly occurred. A reinspection of valves which have been disassembled and reassembled to establish confidence that valves were properly reassembled. i The first three of the above tasks were considered Phase I of this action plan. Phase II of this plan was the fourth task. i The specific methodology is described below: 4.1.1 The first step in this investigation was to identify the population of valves which have been disassembled. All valve disassembly and reassembly was accomplished under operation travelers or Item Removal Notices (IRNs). A log of all operation travelers was reviewed and those pertinent to valve disassembly were utilfred to develop a list of all valves which have been disassembled. The log includes QC Checklists for l valves (QCVs) which accompany IRNs applicable to valve disassembly, i b

4 Revision: 1 Page 4 of 20 RESULTS REPORT ISAP VII.b.2 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) From this list another list was developed of those valves in the population identified in the TRT issue (diaphragm valves in the spent fuel cooling and cleaning system, the boron recycle system, and the chemical and volume control system). 4.1.2 Applicable procedures were reviewed, for both construction and QC, to determine if they provided adequate controle of materials during valve disassembly and reassembly. In addition to proper matching of components, the procedures were reviewed for their adequacy to identify and replace parts damaged during the disassembly, storage and reassembly process. For procedures which changed during the course of construction, the historical file of precedures was reviewed to determine 11 improper reassembly was core likely to occur during a particular time frame. Units 1, 2 and Com=on used the same procedures. In tar =n of valve installation processen, present procedures were viewed as adequate or not, based on their clarity, completeness and on the practicality of their use. 4.1.3 In parallel with the procedure review, an analysis was made to determine the safety consequences of improperly assembled valves. The analysis included potential failure modes resulting from improper reassembly of the generic valves in question. Generic valves are those which required disassembly of all valves of that type. This analysis was to be performed on a case basis for non generic valve types pending the results of reinspections. (As discussed in Section 5, this was not required.) In addition, an evaluation was made to define potential code violations which could result from improperly assembled valves. f 1 I w

Revision: 1 Page 5 of 20 RESULTS REPORT ISAP VII.b.2 - (Cont'd) 4.0 CPRT ACTION Pl.AN (Cont'd) 4.1.4 A reinspection of valves which were disassembled was performed to provide assurance that the valves were reassembled using the correct components. A sample of valven from the population of all valves which were disassembled was reinspected, and an additional sample of valves from the population comprised of the valves identified in the TRT issue was reinspected. Both sampics were in accordance with the sampling criteria guidelines of Appendix D. Sample reinspection was considered to be a reasonable approach for the following reasons: No programmatic deficiencies were identified in Phase I of this ISAP. The population of valves which have been disassembled i t. homoge n e o u r,. Epccit!cally, all the valves were disassembled by the same craft under the same procedures. 4.1.5 Manufacturers drawings and disassembly procedures were reviewed and documentation packages were assembled for those valves selected in the random samples. The inspection procedure was predicated on the results of this review. If review of the documentation for a specific valve indicated probable improper reassembly, reinspection was to include a verification of internal parts. Probable improper reassembly would have been indicated by an inconsistency in internal component serial numbers from one Operation Traveler to another for a particular valve. (As discussed in Section 5 internal verification was not found to be necessary.) 4.2 Procedures Construction and QC procedures now in effect were reviewed for use if disassembly, inspection, reassembly and test of any valves had been necessary as a result of the implementation of this ISAP. 4.3 Participants Roles and Responsibilities s The organizations and personnel that participated in this effort are described below with their respective scopes of work. { [ b

t Revision: l' Page 6 'of 20 RESULTS REPORT ISAP VII.b.2 (Cont'd) 4.0 CPRT ACTION Pl.AN (Cor,t ' d) 4.3.1 TUGC0 Comanche Peak Project Engineering CPPI: 4.3.1.1 Scope Assisted the QA/QC Review Team in the identification and provicion of all necessary specifications, drawings, procedures and other documentation necessary for the execution of this action plan. Assisted in determining the physical location of the valves selected for inspection. Process !;CRs that were renerated due to this action plan. 4.3.1.2 Personnel Mr. C. Mochl:sau 111GCO Coos dinator Mr. D. Snow QA/QC Coordinator 4.3.2 Brown & Root Millwright Shop 4.3.2.1 Scope Disassemble and reassemble valves, as required, for inspection. (As discussed in Section 5, this was not required.) 4.3.2.2 Personnel Mr. C. Hoehiman TUCCO Coordinator 4.3.3 CPRT-QA/QC Review Team 4.3.3.1 Personnel All activities not identified in 4.3.1 and 4.3.2 above were the responsibility of the QA/QC Review Team. L

Revision: 1 Page 7 of 20 RESULTS REPORT ISAP VII.b.2 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.3.3.2 Personne] Mr. M. Obert Issue Coordinator Mr. C. Spinks Inspection Supervisor Mr. J. Adam Safety Significance Evaluation Supervisor Mr. J. L. Hansel QA/QC Review Team Leader 4.4 Qualifications of Personnel Where inspections required the use of certified inspectors, qualification was to the requirements of ANSI N45.2.6 at the appropriate level. CPSES personnel were qualified in accordance with applicable project r eq u i r ete rit c. Third party i n s pe c t o r e: were certified to the requitecents of the third-party employer's Quality Assurance Program and specifically trained to the requirements of the CPSES quality procedures, Other participants were qualified to the requirements of the I CPSES Quality Assurance Program or to the specific requirements of the CPRT Program Plan. 4.5 Sampling Plan r The sampling plan was designed in accordance with the I guidelines of Appendix D, to result in reasonabic assurance that programmatic deficiencies do not exist in the population. The minimum sample size according to Appendix D is 60, with a detection number of zero (i.e., the critical region is one or more deficiencies found in the sample). 4.6 Acceptance Criteria A valve was accepted if the body markings and bonnet markings found in the field were traceable to the Manufacturer's Data Report (Form NPV-1) in the Receipt inspection Report for that valve. Valves which have Permanent Equipment Transfers documenting replacement of valve components and for which the new component was traceable to a form NPV-1 of a valve of identical make, pressure rating, temperature rating, metallurgical type and Code class are acceptable. I e v

e 1 Revision: 1 Page 8 of 20 RESULTS REPORT ISAP VII.b.2 - (Cont'd) 4.0 CP T ACTION PLAN (Cont'd) 4.7 Decision Criteria 4.7.1 The action plan will be closed if the valves which were disassembled and reassembled can perform their intended safety function. Otherwise necessary corrective action will be recommended to meet the design requirements. 4.7.2 If a safety-significant deficiency is found the sample will be expanded and a root cause and generic implication analysis will be done. If deviations are found, trend analysis will be done and for any adverse trend identified a root cause and generic implication analysis will be pe r fo rmed. Any QA/QC Program deficiencies found will be identified to the QA/QC Programmatic Issue Supervisor for analysis. 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS 5.1 Summary of Action Plan Implementation The first step of implementing this action plan was identification of the subject valves in the population. This was accomplished in two ways, First, the generic valves (i.e., those valves which required disassembly by nature of their type) were identified by reviewing installation procedures. It was concluded that ITT-Grinnell supplied diaphragm valves were those addressed in the TRT issue which " required removal of the valve bonnets and internals prior to welding to protect temperature sensitive parts". Additionally, it was found that Borg-Warner supplied check valves were disassembled af ter receipt on site to perform a modification identified by the manufacturer. These two generic valve types were included in the population using a listing of valve tag numbers (unique numbers given to an installed valve) by purchase order. The listing groups che valves according to their manufacturer and type. For these valves an analysis was performed to determine if physical reinspection was required. This analysis lists the possible ef fects of interchanging those parts of the generic valves where parts of one rating or class valve are physically capable of fitting up with,a valve of another rating or class. O

Revision: 1 Page 9 of 20 RESULTS REPORT ISAP VII.b.2 (Cont'd) 5.0 1MPLEMENTATION OF ACTION Pl.AN AND DISCUSSION OF R In addition to the generic valve types requiring disassembly, other specific valves were disassembled for various reasons such as repair, maintenance, or testing. To identify these valves, operation traveler logs were researched. Due to the large number of valve types / sizes in this category and the relatively small number of valves of any given type / size actually disassembled, an analysis such as was performed for the generic valves was not performed unless it was determined during the reinspection program that a deviation was found for a specific valve type. No such cases were found. A population of one thousand three hundred forty-five (1345) valves that were disassembled and reassembled was identified. Approximately seven hundred (700) of these valves were ITT-Grinnell diaphragm valves. From within this overall population a second set of three hundred thirty-four (334) valves was identitied consisting of there valves addressed in the TRT issue (i.e., ITT-Grinnell diaphragm valves in the fuel cooling and cleaning system, the boron recycle spent system, and the chemical and volume control system). The populationa were considercd to te homogeneous for the following reasons: 1. The valves were disassembled by members of the same craft i.e., Brown 6 Root millwrights. 2. All valves were disassembled using the same construction ~and QA/QC procedures. 3. All valves in the sampics could be and were reinspected to the same checklist and attributes and used the same acceptance criteria. A random sample was chosen from both the general population and the TRT issue valves. The samples were randomly selected to obtain at least sixty (60) items from each group in order to achieve the confidence level prescribed in Appendix D of the CPRT Program Plan. During random selection of the sixty (60) valves for the general population some sample overlap occurred. Valves which satisfied the criteria of the TRT issue sample were selected in the general population sample. This required selection of only a sufficient number of additional valves in the TRT issue sample to have afxty (60) valves from each population. Thus, the total number of valves reinspected was one-hundred six (106). I m

Revision: 1 Page 10 of 20 RESULTS REPORT ISAp V11.b.2 - (Cont'd) 5.0 IMP 1.r?.ENTATION OF ACTION PLAN AND DISCUSSION OF RESULT For e.ich valve selected in the samp-le an inspection package was assembled containing the manufacturers drawing, piping isometric, and operational travelers associated with that valve. These documents were reviewed for any indications of incorrect valve reassembly which might require disassembly of the valve for inspection of internal components. To make this determination the travelers were checked for variances in internal component serial numbers. No such cases were found. The valves in the sample were then physically inspected in accordance with QI-018, Reinspection of Previously Disassembled Valves. The purpose of the inspection was to verify that the body and bonnet installed in the field could be traced back to proper documentation showing that they were received f rom the manuf acturer as part of the saec valve assembly or that plant documentation showed replacement of the valve coeponent. Valves which had their body and/or bonnet markings obscured by insulation, paint, etc., were classified as inaccessible and ware replaced by the next randomly = elected valve. Forty-two (42) valves were found to be inaccessible. No bias was introduced as insulation or paint does not effect the methods used for the control of the disassembly / reassembly of the valve. 5.2 Evaluation and Categorization of Inspection Findings No safety-significant deficiencies were found during the course of the reinspection program for this issue. Description of Deviations There were four (4) valid deviations. These were all on ITT-Grinnell diaphragm valves. The deviations consisted of the bonnet assemblies installed on the four (4) valves being different from the bonnet assembly that the Manufacturer's Data Report Form (NPV-1) indicated belonged on the valve. The total of one-hundred six (106) valves reinspected consisted of seventy-nine (79) ITT-Crinnell diaphragm valves and twenty-seven (27) valves from eight (8) manufacturers.

+ Revision: 1 Page 11 of 20 RESULTS REPORT ISAP VII.b.2 (Cont'd) ) 5.0 IMPLEMENTATION OF ACTION Pl.AN AND DISCUSSION O Review of the documents assembled for the reinspection packages revealed one case where the bonnet valve had been lost and one case where the bonnetof a diaphragm had been damaged. These were not considered deviations as they were properly identified by TUGCO using the NCR system and traceability of the installed components was maintained using Permanent Equipment Transfers. The ITT-Grinnell diaphragm valves required disassembly for installation to protect the non-metallic diaphragm from heat damage during welding of the body into the pipe line. The disassembly of the valve is accomplished by unbolting the valve bonnet and lifting the bonnet off the body. The diaphragm and other. internals remain attached to the bonnet so that the valve body and the bonnet. is essentially in two pieces, the Further disassembly of the bonnet is not required for installation. The reason for the deviations being limited to the ITT-Grinnell diaphragm valves is judged to be due to the much greater opportunity for the switching of parta. Gas opportunity arose from there being a relatively large number of this type valve, all of which had to be disassembled to be installed. This resulted in many valve bonnets of the same size and type in storage awaiting reassembly at the same time. The only noticeable difference in the valves would be the marking of the valve tag number on the bag in which the bonnet was kept. Thus the opportunity existed to retrieve the wrong storage bag. No other kind of valve was disassembled in such large numbers at a given time. Two types of ITT-Grinnell diaphragm valves were supplied. first The type is a standard Class 150 valve per ANSI B16.5. class is commonly referred to as the 150 lb. class valves but I This in fact are good for pressures higher than 150 pai depending upon the temperature. The design pressure and temperature of the ITT-Grinnell standard Class 150 valve is 255 pai at 150' F. For some applications valves rated for 300 pai at 150* F were specified. The valves provided for these applications are slightly modified versions of the standard Class 150 valve. These modifications are only made to valve sizes 2". 3". and 4". Other valve sizes are identical irrespective of pressure / temperature rating. ~ JL

Revision: 1 Page 12 of 20 RESULTS REPORT ISAP VII.h.2 (Cont'd) 5.0 IMPLEMENTATION OF ACTION ptAN AND DISCUSSION OF RESULTS (Cont 'd) There are two modifications. The most significant modification is the addition of a support sheet behind the diaphragm to increase diaphragm life by reducing abrasion to the back of the diaphragm operating at the higher pressure. The support sheet is not required for safe operation of the valve. Additionally, the manually operated valves rated at a' design pressure of 300 psi have a brass spindle instead of stainless steel. This is to reduce galling at higher operating pressures. Valves with air operators have stainless steel spindles for both pressure / temperature ratings. The change in spindle material does not affect safe operation of the valve. Both modifications described are made only to improve valve lifetime and do not affect the safety performance of the valve. The valves with design pressure of 255 psi and the valves with design pressure of 300 psi have bonnets and bodies of identical material type and metal thickness and identical diaphrages. Both of the valve types (255 psi and 300 psi design pressure) were supplied to CPSES in ASME Code class 2 and 3. The ASME valves of a given pressure rating are manufactured the same regardless of desired Code class. After manufacturing they are certified to the desired Code class through different post manufacturing testing, with the more stringent testing being performed on Code class 2. only the body of the valve. The difference in testing involves There is no difference in the certification of the bonnets of class 2 and class 3 valves. Therefore, there is no substantive effect of interchanging i class 2 and class 3 bonnets on ITT-Grinnell diaphragm valves. i ,^ Additionally, some non-ASME class diaphragm valves were ( supplied. The difference in non-ASME and ASME manufacturing processes for the bonnets and these valves are all in the level of QA requirements and documentation. The chemical and physical properties identified in the material specifications of the non-ASME and ASME Code class valve bonnets are the Also the post manufacturing testing performed on the same. non-ASME valve bonnets is the same as that for the ASME bonnets, and therefore, the likelihood of an undetected valve l bonnet defect is the same for both ASME and non-ASME valves. It is concluded that there is no substantive effect of i interchanging a non-ASME bonnet with an ASME bonnet on ITT-Crinnell diaphragm valves. b

Revision: 1 Page 13 of 20 RESULTS REPORT ISAP VII.b.2 (Cont'd) $.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION The valve bonnet of a given ITT-Grinnell diaphragm valve size will physically fit up with any valve body of the same size, regardless of their respective pressure / temperature rating or Code class. Any undocumented interchange of one valve bonnet for another discovered during the reinspection was considered a deviation. For two of the bonnets found to be deviations (valve tag no. 2-8422 and 2-7131B), documentation was found in the TUCCO vault substantiating that the valve bonnets installed are identical in pressure / temperature rating and Code class to those which were supposed to be installed. Of the remaining two deviations, one of the valves (valve tag XSF-179) is, a standard (255 psi no. at 150*F) rated valve, ASME Code class 3. Documentation war, not fcund te identify the pressure / temperature rating and Code class et the installed bonnet. However, the bonnet was verifled through markings stamped on the bonnet to be an ASME Code class component so it must be equal to or better than Code class 3. Likewise since only two valve types were supplied to CPSES the installed bonnet must be equal to or better in pressure / temperature rating. The remaining valve deviation (valve tag no. 1-7046) was on a Code class 3 valve rated at 300 psi and 150*F. No documentation was found identifying the installed bonnet it but was verified through markings stamped on the bonnet ASME Code class component as an so it must be equal to or better than required. The reasoning used to classify the deviation as non-safety significant is as follows. Making a worst case assumption, the installed bonnet is assumed to be a standard bonnet. This is a three inch valve. The required bonnet would, at most, have the modification of adding the plastic support sheet. This valve is air operated, so the spindle is stainless steel regardless 01 the bonnet type. Per ITT-Grinnell, use of a standard valve in a 300 psi system is not i recommended; however, lack of the support sheet would reduce diaphragm life but would not prevent proper valve operation. This, coupled with the fact that the valve pressure containing boundary (body and bonnet walls) for both valve types are identical, led to the conclusion of non-safety significance of the deviation. No credit was taken for this valve's expected operating pressure and temperature being substantially lower than even the standard valve's capabilities. J

Revision: 1 Page 14 of 20 RESULTS REPORT ISAP VII.b.2 (Cont'd) 5.0 IMPl.EMENTATION OF ACTION Pl.AN AND DISCUSSION OF RE 1he valved found to have deviations.were installed between early 1979 and late 1981. This was a period of high activity for diaphragm valve installation. It should be noted that the installation travelers for two of the valves, Tag No. 1-7046 disassembled in December, 1980 and Tag No. 2-8422 disassembled in January, 1981, included requirements to record the markings on the bonnets and to verify the numbers at reassembly. This was done and indicates that the valves as originally issued for installation and as currently installed in the plant are the same. This means that the switching of the bonnets occurred prior to their issue for installation. No documentation has been found indicating disassembly prior to instcllation issue, nor any reason found for disassembly prior to issue. 'I h e travelers for the other two valves with deviations were written prior to the practice of recording bonnet =arkings it is unknown when the switching of the bonnets occurred. m Procedure Review Procedures pertaining to valve disassembly / reassembly are designed to: 1. Provide instructions to craft for proper process completion. 2. Provide control for tracking of components (valve bonnets) to ensure removed parts are returned to proper i; locations or to ensure interchanged parts are properly recorded (on PETS). 3. Provide control for identification and proper replacement of lost or damaged parts. The valve installation process was performed under Construction Procedure CP-CPM-6.9, General Piping Procedure including Appendix E. Pipe Fabrication and Installation initially issued in October 1978. From the initial issue of this procedure in October,

1978, through the present time the requirement has existed to perform valve disassembly / reassembly using Construction Operation Traveler's prepared using Construction Procedure CP-CPM-6.3, " Preparation, Approval, and Control of Operation

(

Revision: 1 Page 15 of 20 RESULTS REPORT ISAP VII.b.2 (Cont'd) 5.0 IMPLEMENTATION OF ACTION plan AND DISCUSSION OF RESULTS ( Travelers". installation /inspectica checklistThe operation traveler " serves as a fa of operations necessary to achieve a quality end product". Both CP-CPM-6.9 and CP-CPM-6.3 provide for Quality Assurance participation in both the preparation of the travele r, hold points were included, anc during the actualto ensure. proper inspection disassembly / reassembly. contained a provision thatProcedure CP-CPM-6.9 has also always the parts from disassembled valves be placed in a bag or box which was marked with the valve number. The bag / box was required to be stored in the valve vicinity for large valves or in a secure storage area for smaller valves (ITT-Grinnell diaphragm valves can all be considered small). The early procedures in use did not specifically call for recording on the travelers t he marking stamped on t he valve pieces stored not for QC verification that the came components being reassembled as were were removed. They were adequate, however, if properly followed, to accomplish the disassembly / reassembly of valves with correct components. This conclustoa follcus from rhe requirements to mark the bag containing the disassembled components and to store them in specified areas. The valve storage area at the r111 wright shop was inspected and it was found that valves are currently being marked and stored correctly. The millwright shop personnel are knowledgeable in requirements for equipment component traceability and have these requirements. implemented an effective program to meet These personnel have been in charge since early 1983. Sufficient information for evaluating valve storage prior to this time is not available. The issue related to documentation of interchanging bonnets on the diaphragm valves was recognized by TUCCO and as early as 1980 travelers began to be written requiring that the body and bonnet identification numbers (numbers that are marked on the individual component serial number) be recorded atand are different from the valve assembly the time of valve disassembly. In June, 1983 the procedures were revised and a new procedure. CP-CPM-9.18. Valve Disassembly / Reassembly was issued. This procedure covers valve typea including the ITT-Grinnell diaphragm valves. At the same time Quality Assurance issued

Revision: 1 Page 16 of'20 RESULTS REPORT 1 SAP VII.b.2 - (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) procedure QI-QAP-ll.1-39A Valve Disassembly / Reassembly corresponding to CP-CPM-9.18. This QA procedure specified use of a "QCV" checklist which requires the recording of body and bonnet identification numbers upon disassembly and a verification of the proper numbers at the time of reassembly. This ensures that the proper bonnet is returned to the valve. The requirements of Procedure QI-QAP-11.1-39A have now been incorporated into Ql-QAP-11.1-26, ASME Pipe Fabrication and Installation Inspections. CP-CPM-9.18 allows valve disassembly to be initiated through use of an operations traveler (CP-CPM-6.3) or an 1RN (CP-CPH-6.10). The IRN is used if valves are only disassembled / reassembled without addition of spare parts and disassembly / reassembly procedures are included in CP-CPM-9.18. Otherwise the operations traveler is used. In both cases QC is involved as speciffed in QI-QAP-11.1-26 The QC check 1st used with both the operations traveler and the IRN requires recording of the bonnet identification numbers. Administrative actionc were taken in mid-1985 to ensure the above requirements were fully implemented in the startup test program. The current program provides the controls necessary to ensure: 1.- Proper installation of valve components and 2. That non-conformances (lost or damaged parts or interchanges affecting performance characteristics) will be identified and corrected. The example of a lost valve cited by TRT in SSER-Il is not unexpected in a large project. The procedures are structured to detect such problems. The particular instance mentioned was detected by the project and documented on a Nonconformance Report, thereby demonstrating that the procedure system is working as designed to identify and correct any lost or damaged parts. 5.3 Trend Analysis A trend analysis was performed for the four (4) valid deviations found. All deviations were found in ITT-Crinnell diaphragm valves. It is significantly less likely that similar deviations exist in valves other than ITT-Crinnell valves for the following reasons:

Revistor. 1 Page 1: of 20 RESULTS REPORT ISAP VII.b.2 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Co 1. These valven (non-diaphragm).were not disassembled such that large numbers of compatible valve parts were available for interchange as was the case with the ITT-Grinnell diaphragm valves. Even though all the valves were disassembled by the same craft and under the same procedural control, the valves other than ITT-Grinnell diaphragm valves were less likely to be interchanged as there was less potential. 2. Of the valves other than ITT-Grinnell diaphragm valves reinspected, no valid deviations were found. For the ITT-Grinnell diaphragm valves, ft was determined that the effect of using a valve bonnet rated at 255 psi on a valve body rated for 300 pai would not cause a safety-significant deviation in any instance. This comes from the fact that the preunure boundaries of the valve and the diaphragm are identical for both ratings. The only differences (diaphragm support sheet and brass spindle in higher rated bonnet) are for increased life / reduced maintenance and are not required for the safe operation of the valve. No deviations in code class were found so no trend for code class violations exists. The non-ASME and ASME Code class valve bonnets are manufactured by the same physical process and use the same materials. Additionally, the post manufacturing testing of the non-ASME bonnets is the same as for the ASME bonnets. While the potential for switching non-ASME and ASME Code class bonnets did exist, there is no implication that switching of non-ASME and ASME valve bonnets could be safety-significant. Therefore, the four deviations were not judged to be an adverse trend. 5.4 Root Cause and Generic Implication Evaluation The reinspection program found no construction deficiencies. No adverse trend exists. Therefore, no root cause or generic implication analyses were required. ~

[ Revision: 1 Pag ~e 18 of 20 RESULTS REPORT ISAP VII.b.2

• (Cont'd)

$.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont 'd) The NRC hypothesized root cause that the process for valve disassembly / reassembly was not controlled was partially substantiated. The lack of adequate control was limited to ITT-Crinnell valves that were disassembled in large numbers at the same time. Although the procedures at that time appeared adequate to accomplish the disassembly / reassembly of valves correctly, they did not contain requirements to record and verify valve bonnet identification numbers, and undocumented interchanges occurred as large numbers of assembly / disassembly operations were performed with similar valves. The procedures were strengthened in June, 1983. The problem does not extend to the general population because large numbers of other types of valves were not disassembled at the same time. The results of our invest igation support this. 5.5 Evaluation of Results Against Action Plan Decision Criteria No construction deficienciec were four.d. T1.e valves found with deviations were determined to be able to perform their intended functions under the design conditions. Therefore, the action plan is to be considered closed. This action plan required expansion of the sample upon finding one or more construction deficiencies. Since none was found, the sample was not expanded. 5.6 Identification and Discussion of Corrective Action The programmatic requirements to preclude switching valve bonnets at the time of reassembly have already been addressed by TUCCO. The change of personnel and revamp of the millwright valve storage area in February,1983, should act to minimize loss, damage or inadvertent interchange of valve bonnets. The procedures in place since mid-1983 requiring the verification during reassembly that the body and bonnet identification numbers match those when the valve was disassembled preclude an inadvertent and undetected switching of the valve bonnets. The specific valves found with deviations have been identified to TUGC0 and have been entered into the TUGC0 Non-conformance Report (NCR) system. t b. n

Revision:; ~ 1 Page 19 of 20 RESULTS REPORT ISAP VII.b.2 (Cont'd) $0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont 'd) 5.7 Out of Scope observations During the course of reinspection, thirteen (13) valves were found to have the required code data tag missing. This tag lists the manufacturer's name and serial number, Code class, pressure / temperature rating, and year built. These valves were identified to TUCCO and NCRs written covering this observation. TUGC0 had already identified a problem with missing code data tags and has in place acceptable procedures for handling missing data tage. The absence of these tags has no effect on the performance or safety of the valves. No other out-of-scope observations were noted during implementation of this action plan.

6.0 CONCLUSION

S Two valid deviations were found in the sample from the general repu3ation cf vcives disansembled and reassembled, one of whicn was also part of the TRT issue population. Two more valid deviations were found in the additional samples selected just from the TRT population. No construction deficiencies and no code-class deviations were found in the samples. A safety significance evaluation has shown that no construction deficiencies can occur on the ITT-Grinnell valves due to interchanged parts occurring during reassembly of disassembled valves. Based on the results of the reinspection program the following conclusions are drawn: There is a 95 percent confidence that at least 95 percent of the general population of valves that were disassembled were reassembled in a functionally correct manner and have no pode class deviations (i.e., zero construction deficiencies or code class deviations found in a sample of sixty). There is a 95 percent confidence that at least 95 percent of the TRT issue valves (i.e.. ITT-Grinnell valves in the spent fuel cooling and cleaning system, the boron recycle system, and the chemical and volume control system) that were

v s, , 7mvi= Aon: - 1 Page 20 of 20 RESULTS REPORT ISAP VII.b.2 (Cont'd) 7.0 ONGOING ACTIVITIES (Cont'd) disassembled were reassembled in a functionally correct manner and have no code class deviation (i.e., zero construction deficiencies or code class deviations found in a sample of sixty). The procedures for valve disassembly / reassembly were reviewed and determined to provide adequate control requirements except in cases where large numbers of similar valves were simultaneously disassembled 7-Furthermore, no instances were found that the control proccis broke down except in the case of the ITT-Grinnell valves. The improvements made to the control process since 1983 provide reasonable assurance that an adequate control process is in - placc. The four deviations occurred on ITT-Grinnell diaphrage valves in a tiec frame when relatively large numbers of valves were disassembled at the same time. This fact, along with confidence in the process for the control of valve disassembly /rencaembly, indicates that uncontrolled switching of valve bonnets does not extend to the generai population. ~ ~ - - 7.0 ONGOING ACTIVITIES The SRT considers the implementation of VII.b 2.to be complete. The disposition of the NCRs for the four de'viations will correct the "as installed" documentation for the valves. + The assessment of TUCCO's handling of programmatic corrective action regarding control of valve disassembly / reassembly will be addressed in ISAP VII.a.2. 8.0 ACTION TO PRECLUDE OCCURRENCE IN THE FUTURE As previously discussed the control process currently in ef fec*t is h adequate to ensure proper valve disassembly /resssembly. I Additionally, discussions with millwright supervision and the supervisor of the valve storage area in the millwright shop revealed an appreciation for the need to maintain proper material traceability. L. ~

e r 1 ~ COMANCilE PEAK RESPONSE TEAM i ACTION Pl.AN ISAP VII.b.2

Title:

Valve Disassembly i. l Revision No. 0 1 4 Reflects Coninents Description Origir,1 Issue On Plan Prepared and Pecom.end:d b-- Review Team Lender & ZsffC, ll2tll% Date i i i i t Approved by: h,. d./[ L h,pW_ks Senior Review Team 4 f11f t( /lZ4lEL Date L i I l /' DU g

.8 t ' Revision: 1 'Page 1 of 7 ( ISAP VII.b.2 \\ Valve Disassembly

1.0 DESCRIPTION

OF ISSUE IDENTIFIED BY NRC t (USNRC letter of January 8, 1985, Pg. 23) "The TRT found that installation of certain butt-welded valves in three systems required removal of the valve bonnets and internals prior to welding to protect temperature-sensitive parts. The three systems involved were the spent fuel cooling and cleaning system, the boron recycle system, and the chemical and volume control system. This installation process was poorly controlled in that disassembled parts were piled in uncontrolled areas, resulting in lost, damaged, or interchanged parts. This practice created the potential for interchanging valve bonnets and internal parts having different pressure and temperature ratings." i 2.0 ACTION IDENTIFIED BY NEC Evaluate the TRT findings and consider the implicatiens of these findings on construction quality. "... examination of the potential safety implfcations should include, but not be limited to the areas ~ or activities selected by the TRT." " Address the root.cause of each finding and its generic implications..." " Address the collective significance of these deficiencies..." " Propose an action plan...that will ensure that such problems do not occur in the future."

3.0 BACKGROUND

Other possible reasons for valve disassembly include hydrotest, flushing, purging and repair, and therefore many different valve types are potentially affected. j Additional background information such as valve manufacturers, { types, sizes, ratings, installation dates, etc. will be obtained as a part of the implementation of this issue-Specific Action Plan. L

Revision: 1 Page 2 of 7 ISAP Vll.b.2 (Cont'd) 4.0 CPRT ACTION PLAN 4.1 Scope and Methodology The objective of this action plan is two fold. Firstly, to evaluate if procedures are adequate to control the valve disassembly / reassembly process. Secondly, to evaluate if valves that required disassembly were properly reassembled; and, if not, whether an improperly reassembled valve could result in a code violation or have a safety consequence. The following tasks will be implemented to achieve these objectives: Identify all valves which have been disassembled and reassembled. A procedure review to determine adequacy of control of valve components during disassembly and reassembly. A safety consequence analysis to determine if valve component parts from one valve are physically capable of fitting up to another valve of the same type but having a lower pressure / temperature rating or code class and identify potential risks if such reassembly occurred. A reinspection of valves which have been disassembled and reassembled to establish confidence that valves were properly reassembled. The first three of the above tasks shall be considered Phase I of this action plan. Phase II of this plan vill be the fourth task. The specific methodology is described below: 4.1.1 The first step in this investigation will be to identify the population of valves which have been disassembled. All valve disassembly and reassembly was accomplished under operation travelers. A log of all operation travelers will be reviewed and those pertinent to valve disassembly will be utilized to develop a list of all valves which have been disassembled. I b

Revision: 1 Page 3 of 7 ISAP Vll.b.2 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) From this list another list will be developed of those valves in the population identified in the TRT issue (diaphragm valves in the spent fuel cooling and cleaning system, the boron recycle system, and the chemical and volume control system). 4.1.2 Review applicable procedures, for both construction and QC, to determine if they provided adequate controls of mate:ials during valve disassembly and reassembly. In addition to proper matching of components, the procedures will be reviewed for their adequacy to identify and replace parts damaged during the disassembly, storage and reassembly process. If procedures have changed during the course of construction the historical file of procedures will be reviewed to determine if improper reassembly were more likely to occur during

4. particular ti=c frame. If the procedures for Units 1, 2 and Common are different, they will each be evaluated.

In terms of valve installation processes present procedures will be viewed as adequare or nor ha=*d on their clarity, completeness and on the practicality of their use. 4.1.3 In parallel with the procedure review, an analysis will I be made to determine the safety consequences of i improperly assembled valves. The analysis will include I potential failure modes resulting from improper l reassembly of the generic valves in question. Generic I valves are those which required disassembly of all valves of that type. This analysis will be performed on a case basis for non generic valve types pending the results of reinspections. In addition, an evaluation will be made to define potential code violations which could result from improperly assembled valves. 4.1.4 A reinspection of valves which have been disassembled will be performed to provide assurance that the valves were reassembled using the correct components. A sample of valves frem the population of all valves which have been disassembled will be reinspected and an additional sample of valves from the population comprised of the valves identified in the TRT issue J

~ Revision: 1 Page 4 of 7 ( ISAP VII b.2 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) will be reinspected. Both samples will be in accordance with the sampling criteria guidelines of Appendix D. Sample reinspection is c'onsidered to be reasonable approach for the following reasons: No programmatic deficiencies have been identified in this population to date. The population of valves which have been disassembled is homogeneous. Specifically, all the valves were disassembled by the same ~ craft under the same procedures. Therefore, sampling in accordance with Appendix D will detect, with a high level of accuracy, programmatic errors associated with the process of disassembling and reassembling valves. 4.1.5 Manufacturers drawings and disassembly procedures will be reviewed and documentation packages will be assembled for those valves selected in the random sample. Inspection procedure will be predicated on the results of this review. If review of the documentation for a specific valve indicates probable improper reassembly, reinspection will include a verification of internal parts. Probable improper reassembly will be indicated by an inconsistency in internal component serial nos. from one Operation Traveler to another for a particular valve. 1 4.2 Procedures Operations, construction and/or QC procedures now in effect will be reviewed and if found satisfactory, will be used for disassembly, inspection, reassembly and test as required. 4.3 Participants Roles and Responsibilities The organizations and personnel that will participate in this effort are described below with their respective scopes of t work. i (

kevision: 1 Page 5 of 7 ( ISAP VII.b.2 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.3.1 TUGC0 Comanche Peak Project Engineering CPPE 4.3.1.1 Scope Assist the QA/QC Review Team in the identification and provision of all necessary specifications, drawings, procedures and other documentation necessary for the execution of this action plan. Assist in determining the physical location of the valves selected for inspection. Process NCRs that may be generated due to this action plan. 4.3.1.2 Personnel l Mr. C. Moehlman TUGC0 Coordinator 4.3.2 Brown & Root Millwright Shop 4.3.2.1 Scope Disassemble and reassemble valves, as required, for inspection. 4.3.2.2 Personnel Mr. C. Mochiman TUGC0 Coordinator 4.3.3 CPRT-QA/QC Review Team t 4.3.3.1 Personnel All activities not identified in 4.3.1, and 4.3.2 above will be the responsibility of the QA/QC Review Team. 4.3.3.2 Personnel l Mr. M. Obert Issue Coordinator i Mr. C. Spinks Inspection Supervisor 4; ,I

F Revision: 1 Page 6 of 7 1 ISAP VII.b.2 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) Mr. J. Adam Safety Significance Evaluation Supervisor Mr. J. L. Hansel QA/QC Review Team Leader 4.4 Qualifications of Personnel Where inspections require the use of certified inspectors, qualification will be to the requirements of ANSI N45.2.6 at the appropriate level. CPSES personnel vill be qualified in accordance with applicable project requirements. Third-party inspectors will be certified to the requirements of the third-party employer's Quality Assurance Program and specifically trained to the requirements of the CPSES quality procedures. Other participants will be qualified to the requirements of the CPSES Quality Assurance Program or to the specific requirements of the Program Plan. 4.5 Sampling Plan The sampling plan will be designed in accordance vieh tha guidelines of Appendix D, and will result in reasonable assurance that programmatic deficiencies do not exist in the population. The minimum sample size according to Appendix D is 60, with a detection number of zero (i.e., the critical region is one or more deficiencies found in the sample). If one (1) deficiency is found, the sample will be expanded to 95, and the root cause of the deficiency will be evaluated. If no further deficiencies are found, and the deficiency from the first sample is determined to be non-programmatic, it will be concluded that the population passes the requirements of Appendix D. If the number of deficiencies discovered is large (i.e., two or more), cir a potential root cause is identified as programmatic, a 100* reinspection and record review of the population will be performed. 4.6 Acceptance Criteria A valve will be accepted if the body markings and bonnet markings found in the field are traceable to the Manufacturer's Data Report (Form NPV-1) in the Receipt { Inspection Report for that valve. Valves which have Pe rmanent Equipment Transfers documenting replacement of valve f,

Revision: 1 Page 7 of 7 ( ISAP VII.b.2 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) components and for which the new component is traceable to a form NPV-1 of a valve of identical make, pressure rating, temperature rating, metallurgical type and code class are acceptable. 4.7 Decision Criteria 4.7.1 The action plan will be closed if the valves which have been disassembled and reassembled can perform their intended safety function. Otherwise necessary corrective action will be recommended to meet the design requirements. 4.7.2 If a safety-significant deficiency is found the sample will be expanded and a root cause and generic implication analysis will be done. If deviations arc found, trend analysis will be done and for any adverse trend identified a root cause and generic implication analysis will be performed. Any QA/QC Program deficiencies found will be identified to the QA/QC Programmatic Issue Supervisor for analysis. L

4 Page 1 of 2 (f ( ( EViUDNTROLLE TION RESEARCII CORPORATION CONTROL No. D COPYg COMANCllE PEAK RESPONSE TEAM QUALITY INSTRUCTION FOR ISSUE SPECIFIC ACTION PLAN VII.b.2 CHANGE NOTICE 001 INSTRUCTION NO: QI-018 REVISION: 0 ISSUE DATE: 09/19/85 FEINSPECTION OF PREVIOUSI.Y DISASSEMBLED VALVES j The QI identified above is hereby changed as i shown on the attached pages of this notice. I i Prepared by: ~ Date: 7 /P I / / Approved by: Date: 9 f Issue Coordinator

1. )

0 Approved by: h /t/. /M Date: 7 -/9 - 7f On-Site QA' Representative i Approved by: Date: f /f TJ~ Q Review Team Leader w

O. Z co V11.b.2 Valve Disassembly QUESTION: 1. Section 4.1.2 of the Results. Report states, "in addition to proper matching of components, the procedures were reviewed for (sic) damage during the disassembly, storage and reassembly process." Please provide the results of this review.

RESPONSE

As discussed in the " Procedure Review" portion of Section 5.2 (page 14 through 16) of the Results Report, the procedures used for valve disassembly - CP-CPM-6.9 or CP-CPM-9.18 - have always contained provisions to package disassembled valve parts. The purpose of this packaging (in a heavy duty plastic bag or wooden box marked with the valve tag number) as stated in CP-CPM-9.18 is "to prevent loss or damage and to maintain traceability." This practice was found to be adequate to identify damaged parts. Additionally, the operational travelers and QC checklist for valves (QCV's) reviewed during the sample reinspections all contain a sign off by the craftsmen, QC engineer, or in the vast majority of cases - both, verifying all internals have been cleaned / prepared for reassembly. This constitutes a final check for visible damage prior to reassembly.

See, e.g., action plan working file Section 5.0 (Item 1-M-VALV-122).

QUESTION: 2. Section 5.2 (page 12 of 20, last paragraph) addresses differences in non-ASME and ASME manufacturing processes for the bonnets. The Results Report states that physical and chemical properties identified in the material specification would be the same for both and also that post manufacturing testing would be the same. Please address how you considered the differences between ASME Code and commercial requirements such as material identification and traceability, welding and weld repairs, personnel qualifications, and nondestructive examinations. '}

RESPONSE

The conclusion as stated in the Results Report is that there is "no substantive ef fect of interchanging a ASME bonnet with a non-ASME bonnet on ITT Grinnell d.aphragm valves." This conclusion was based on discussions with the manufacturer's QA Division Manager as documented in the action plan working file number 9.0 item 9.0-25 (copy attached). It was recognized that there are differences in the quality assurance programs under which the ASME and commercial grade bonnets are manufactured, but this was determined not to be significant in this particular instance since post manufacturing testing is identical for both ASME and non-ASME (commercial) bonnets, &/ 12 NRC j

VII.b.2 Valve Disassembly (Cont'd)

RESPONSE

The evaluation for potential code class violations mentioned in the second paragraph of Section 4.1.3 was done as part of the analysis discussed in the first paragraph of this section. This analysis is contained in the action plan working file as document no. 6.0, itee 6B-6 (copy attached). Revision 1 dated 11/25/85 of the analysis was inadvertently omitted from the action plan file and has now been added. QUESTION: 6. Section 4.1.4 first sentence states that reinspection of valves which were disassembled was performed to provide assurance that the valves were reassembled using the correct components. It is not clear how, or from what documentation, the correct components were identified. RESPCNSE: The acceptance criteria are stated in Section 4.6 of the Results Report. QUESTION: 7. Section 4.2 procedures are not identified per program plan attachment 3 ISAP format.

RESPONSE

The procedures in effect are CP-CPM-9.18 Rev. O, dated 6/8/83 and QI-QAP-11.1-26 Rev. 18, dated 12/19/85. QUESTION: 8. Section 4.6 appears to apply to only diaphragm valves - what was the basis acceptance of other types of valves with interchangeable top works and trim.

RESPONSE

The criteria of Section 4.6 applied to all valves inspected under this action plan. QUESTION: t 9. Section 5.1 second paragraph states that the review installation procedures, revisions and dates should be identified. I 15 NPC

VII.b.2 Valve Disassembly (Cont'd)

RESPONSE

This information can be found in action plan working file 6A, items 6A-1 and 6A-2 (copies attached). QUESTION: 10. Section 5.0 page 11 first paragraph states that a lost bonnet and a damaged bonnet were not deviations because they were properly identified on NCRs and PETS. The valve type, size, gag numbers, date of installation, the NCR and PET ' numbers should also state if the NPV-1 form was revised, or annotated.

RESPONSE

The NCR and/or PET associated with these valves, or any similar conditions, serve as the key to initiating any required code documentation relative to the repair or replacement. When NPV-1 certified parts of a component are replaced or repaired, an ASMI Section X1 NIS-2 form is executed to maintain component certification acceptability; this form is completed prior to N-3 certification c,f the Unit, and is utilized in lieu of annotating or revising an ASME Section III NPV-1 Data Report, which is not permitted by the Code. QUESTION: 11. Section 5.0 page 11 fourth paragraph states that two types of ITT Grinnell valves were supplied. This paragraph should also provide complete identification of the valve types (manufacturer's drawing or identification numbers), valve sizes, rating and applicable code class.

RESPONSE

This information can be found in action plan working file 6.0, item 6B-5 (copy attached). (Note that the Generic Safety Consequence Analysis attached to this item is superceded by Revision I which is provided in response to item no. 5 above.) QUESTION: 12. Section 5.0 fifth paragraph states in part: For some application...the applications should be identified (page 11).

RESPONSE

The applications of the valves rated 300 psi at 150' F. were those within the scope of the NSSS Vendor supply. Westinghouse always specifies this type valve regardless of the application, system or plant for which their NSSS is supplied, for reason of standardization. 16 NRC

VII.b.2 Valve Disassembly (Cont'd) The ITT Grinnell standard valve discussed in paragraph four of page 11 of the Results Report is used in all non-NSSS applications. QUESTION: 13. Section 5.0 page 12 first paragraph is not clear in its description of valve modifications. 1-were the modifications made specifically for CPSES valves at the specified 300 PSIG, or 2-are these valves just different configurations furnished by the supplier when the user specifies service conditions, pressure / temperature, that are higher than design.

RESPONSE

See response to question no. 12. QUESTION: 14. Section 5.0 page 13 second paragraph, identifies two valves by tag numbers. This paragraph should further identify the manufacturer's drawing or identification number, size, rating, code class and date of installation. Additionally this paragraph should identify the documents (e.g., NCR, IR, PET) that substantiated acceptance of the installed valve body and bonnet.

RESPONSE

The information requested is: Valve Tag No. 2-8422 Mfg. Dwg. No. - SD-C-100552 Rating 300 psig at 150*F. Class 2 Size - 3" Install. Traveler No. MW81-1105-4900 Reinspection Pkg. No. - I-M-VALV-44 dated 10/16/81 Valve Tag No. 2-7131B Mfg. Dwg. No. - SD-C-100551 Rating 300 psig at 150*F. Class 3 Size - 3" Install. Traveler No. MW7980361-4100 Reinspection Pkg. No. - I-M-VALV-56 dated 10/23/79 This information is in the reinspection packages found in action plan working file Section 5.0. The acceptance of the installed valves is documented on the installation traveler. No NCR or PET was in effect documenting the deviation at the time of the CPRT inspection of the valve which is the reason the deviation was declared. 17 NRC

t VII.b.2 Valve Disassembly (Cont'd) QUESTION: 15. Section 5.0 page 13 the second and third paragraphs, identify two valves by tag number. These paragraphs should also identify the manufacturer's drawing or identification number, size, ratiag and code class and date of installation.

RESPONSE

This information is: Valve Tag No. 1-7046 Mfg. Dwg. No. - SD-C-101609 Rating 300 psig at 150*F. Class 3 Size - 3" Install. Traveler No. MW80-1020-4900 Reinspection Pkg. No. - I-M-VALV-9 dated 11/11/81 Valve Tag No. XSF-179 Mfg. Dwg. No. - SD-C-105686 Rating 255 psig at 150* F. Class 3 Size - 3" Install. Traveler No. MW79-081-4700 Reinspection Pkg. No. - I-M-VALV-67 dated 12/19/79 This information is in the reinspection packages found in action plan working file section 5.0. QUESTION: 16 Section 5.0 page 14 first paragraph states that because the installed valves (with deviations) match the numbers recorded on the operations travelers, this means that the bonnets were interchanged prior to issue for installation. The staff finds that this deduction may not be valid if the valve was disassembled, installed and reassembled on the same day. If the traveler records these operations as performed on the same date (same shift), there is t.o assurance that the required information was recorded prior to disassembly. Another potential is the switching of valve tags. REC'ONSE: The installation of these valves, as documented on the installation traveler in the reinopection packages, showed that the valve bonnets were removed and stored for a period of months, and then reascembled when all welding was complete and the line was installed in the field. Switching of valve tags would not cause the noted deviations as numbers stamped on the valve body and bonnet were used for the reinspection. 18 NRC

VII.b.2 Valve Disassembly (Cont'd) QUESTION: 17. Section 5.0 page 14 second paragraph relates to travelers for the other two valves that were written prior to the practice of recording bonnet markings... This paragraph should identify the two valves in question, the date installed, the procedure and applicable revision at the time of installation.

RESPONSE

The valves in question are valve tag nos. 2-7131B and XSF-179 discussed on page 13. They were installed under procedure no. CP-CPM-6.9 Rev. O, dated 10/6/78 on 10/23/79 and 12/19/79 respectively, based on traveler completion dates. QUESTION: 18. Section 5.0 page 15 second paragraph refers to early procedures. The specitle procedures, revisions and dates should be identified.

RESPONSE

CP-CPM-6.9 Rev. O was the project source procedure which contained integrated Construction / QC direction for the disassembly / reassembly or valves on CPSES. CP-CPM-6.9 was divided into subsections shortly after its issuance, and the requirements for valve disassembly / reassembly were then encompassed in CP-CPM-6.9E. CP-CPM-6.9/CP-CPM-6.9E Rev. 0 (2/6/80) set forth the following requirements with respect to valve disassembly / reassembly: Detailed instructions, including the general requirements of CP-CPM-6.9/CP-CPM-6.9E, would be provided to Construction /QC via an Operational Traveler (OT), prepared and approved in accordance with CP-CPM-6.3; and, Section 3.14 of CP-CPM-6.9/CP-CPM-6.9E requires, in part "All parts removed from the valve shall be stored in a heavy duty plastic bag, or in the case of a large valve a wooden or cardboard box. The MS [M111 wright Superintendent] shall mark thn box / bag with the valve number. "Any valve that will remain dismantled for an extended period of time will have the bag / box of parts stored in a secure place in the M111 wright Shop or Warehouse. If the MS estimates that the valve will remain disassembled for only a short period or that it is too large to be easily removed from the work area, then the bag / box may remain in the field." 19 NRC j

Vll.b.2 Valve Disassembly (Cont'd) The above requirements remained as written through DCN #5 to CP-CPM-6.9E Rev. 6 (8/1/83), at which time they were deleted and CP-CPM-9.18 (Rev. O, 6/8/83) was referenced. Additionally, Quality Instruction QI-QAP-11.1-39A Rev. O was issued on 6/8/83 to prescribe specific QC inspection and documentation requirements for valve disassembly / reassembly. Additional details can be found in action plan working file 7.0, items 7.0-1 and 7.0-2 (copies attached). QUESTION: 19. Section 5.0 page 15 third paragraph last sentence states; sufficient information for evaluating valve storage prior to this time is not available. The issue of concern was the storage of disassembled valve components. The TRT found that the storage at installation locations was poorly controlled. The paragraph should address the storage of disassembled valve components. Additionally, this paragraph refers to an effective program implemented by Mi11 wrights. This " Effective Program" should be addressed in the aspect of the implementation of an identified procedure and the verification of training of millwright personnel in the applicable procedure.

RESPONSE

The Results Report does refer to the storage of valve parts. It was intended to relate that the Millwrights had effectively implemented the existing program. See response to Question 18. Records for the training of Millwright personnel are on file in the Construction Department Training Records. QUESTION: l 20. Section 5.0 page 15 the fourth paragraph states that the issue related to documentation of the interchange of valve bonnets was recognized by TUGCO... This paragraph should state the basis (NCR's, irs etc.) for TUGCO's recognition and address this subject by including the identification of the procedures, revisions and dates. 20 NRC

VII.b.2 Valve Disassembly (Cont'd)

RESPONSE

The RTL did not identify a specific event or discrete occurrence. The recognition was manifest by the recording of body and bonnet numbers on trcvelers which began in late 1980. This was a general practice within existing procedures. It was formally proceduralized by TUGC0 with the issuance of CP-CPM-9.18 Rev. O in June 1983. QUESTION: 21. Section 5.0 page 16 the second paragraph states that the QC checklist requires recording of the bonnet identification number. For the installation of valves, since valve tags can also be interchanged, the staff finds that the procedure should require that the checklist should record both the body and bonnet identification.

RESPONSE

As stated in the first paragraph on page 16 of the Results Report, the checklist does require recording of both body and bonnet identification numbers stamped on the valve parts. QUESTION: 12. Section 5.0 page 16 third paragraph states the administrative action was taken (by TUCCO) in the startup test program. The administrative action should be identified in terms of identification of any applicable procedures, revisions and the CPRT verification of the training of personnel.

RESPONSE

The administrative action taken by TUGC0 in 1985 was to require i control of all work processes during the construction phase of CPSES, through implementation of the work package concept defined in the CP-CPM-7.1 series of procedures. Verification of program implementation and the awareness of project personnel with the program was evident from the process in which CPRT was required to obtain project documentation, prepare inspection packages and initiate work processes. The only question of applicability during implementation of the CP-CPM-7.1 (series) involved the Start-up Organization, which, as documented in the action plan working file 7.0 item 7.0-4, was resolved by letter CPPA #45,538. 21 NRC I

VII.b.2 Valve Disassembly (Cont'd) QUESTION: 23. Section 5.0 page 16 the fourth paragraph cites an example identified by the TRT as evidence of procedure implementation and effectiveness. The TRT also identified (in SSER-II) numerous PETS that documented the interchange as replacements for lost and/or damaged valve components. The staff wishes to emphasize that the issue essentially was procedural inadequacy to control the interchange, loss and damage of disassembled valve components. The staff disagrees with the CPRTs reasoning that this is an example of procedure effectiveness. The TRT stated that although the deficiency was reported on the NCR, and procedures were in place, the loss and damage continued to occur.

RESPONSE

See the response to question 4. QUESTION: 24. Section 5.6 page 18 identification and discussion of Corrective Action first paragraph is vague. The paragraph should identify the level of responsibility of the changed personnel and identify the procedure, revisions and dates as they apply to the subject of this paragraph.

RESPONSE

As addressed in response to questions 18 and 19, the corrective action was to implement effectively the existing progran rather than developing a program to implement. Implementation was effected at the craftsman level and procedural compliance was and is stressed at the supervisory levels. QUESTION: 25. Section 5.7 page 19 Out-of-Scope Observations. The paragraph refers in part to: acceptable TUCCO Procedures... The procedures should be identified.

RESPONSE

CP-QAP-12.4 Rev. 1, dated 12/28/83, 22 NRC 4

e VII.b.2 Valve Disassembly (Cont'd) QUESTION: 26. Section 6.0 page 20 the second paragraph states that procedures were reviewed and found to be adequate except for.. and further, the last sentence states that improvements to the control process since 1983... The procedures, revisions and dates should be identified, and the improvements to the control process should be specifically detailed in this paragraph.

RESPONSE

See response to question no. 18. QUESTION: 27. Section 7.0 page 20 does not clearly identify any of the results of the implementation of this plan (e.g., procedure inadequacy, lack of control, etc.) that must be addressed by TUCCO, and then evaluated under ISAP VII.a.2.

RESPONSE

TUGCO must disposition the 4 identified via the Project NCR process. No programmatic concerns were identified during the conduct of this ISAP (See response to question 20). ISAP VII.a.2 will assess handling of any programmatic corrective actions by TUGCO. One of the specific allegations being investigated in ISAP VII.a.2 is the portion of the TRT issue on valve dis / reassembly (as stated in AQ-52 of SSER-11) that concerns " effective programmatic corrective action was not implemented... i 23 NRC lJ

e I w-

'3

~7 q ~ ) I b I 16 s t %%l eY i >T C ~ s e, s4i l v 3 cNx- \\N. .ts T (- M

n e

5 f r 5,, 'w K N s ~ .z ,s s, ~ 4 s is s i -c q v. s e ~ y w, r. L \\ 4: o s.. .i, t s 2 (; k 'N s () 's ^ 0 .A s ( .Q 4 4

i. s.

N> s s U. s w y g .s s s 5 )A N O 34 4 ~,1 N

• ol k!. <* P4 4

't i '4: ci T% f Y ' (t vo u c" OV o p!( e V 9 I .M. f.,'w? T E' c4s u. ' q h .: g F i - oN l b 7*'SN ( g 3 NO 4 d, .j c. r- % - %l $C 7 % \\ G 4 .\\ % i f O C 5); N t 0 * \\ -S'. iN 3

c..o s

Nn b u s. ss t e.4,1'. 0. S 5 h h 7, w 4 ~ = >. : s. .N S c

• 9".'

(* C <e. t R o-t s9 h G. 5 ,5> e:: =: c 4O c' g o s i w; 8 ng L 4

-l

6 %.%l0E 5 "

t rs s'A 4 g s 1 e t i I f d[ b ". h l 1 Q 1* l s \\ b 3 N i I i. E-e .A. w 6 E C0 3 b W \\ at 7 -- m C G V 7 06 4 W= sD 4> 4 d d U C .t h 4 a = p .e b

== ag 7 - s. - f 4.;

a es== t Tc a

e. t> 04 O - *: b .& O a .L 7. i

• u U

C= u e. 3 M : = M.4 .e 14 =-b 4 :

• O c

= se =00 0-4 =d d 6 .e - 4

=0 3

.e ed 6-e c0m .a O JC = ** t 3 T O COC C.* - UA D W

==# T "O C O. d m /= = * < b (.:

• 2 3mC 4
• O LO-

-t en C=u e .e ' eN A .C [' U C a t% C e J 3 6 : 0; b1 b.

• J T>

J C b.T O 3 u :. - 3Ca = = u / CD: O

s

)w Oc e 3 Sw =.. V. s e =ne -c; M C.

m. c n.

.u -a - =;*

s..

.o Ce > -m s.a =u o 4m J E-C e = = .W s e ta E== N a s '. : tu - >s .au - = ba m v3 g s : 3

E 3

- c -w -., m -< c = c-- m at t: ee-e== 0e ce b8 s, -L =a < = - 2-

==- : > ;, e-

0-a>

C

-0

-;; / - 2 n.L. 0 = -.: 0-U -S

A i

' ?, E4A E> E<> . :s EA4 =>

e u

-t .E t -

;e

- 3

.r. ;;

• mn zo

./ l D s N J i a a '44 5 i E -N ..g a. i g 4 a s s N- ' T 2 Y . L* 'f b = = - c = = ': 3 e e = = = 3 2 : '. = = c = e.s V rT r.s .. t es. .N 2 tw e.v..% = d. y e h.. ** :E. e - e e g; b n

v. Y sn u.

i .9

n (

en 9 P ( ( O% t.* T. E K. eE a e >- e Q= = g, a

• m A

s .a. g

r, e e a a

e. e e g I Y7 ? u ~ v s, s g s f -N < C.i m, ge ~ nb S'l N v L 5 N 4l c I ) sk 8 b CJ b N 4 ^N n s >1 l 0& op9 ' \\ k N q -> t. n, i % y r u = i> - c,- i ~ 6 es a f i h w; / 0 $. O i N C % C-s %1

• l-4 %

e 0, ~ 1 foi j y $ tv ' l { ,.a I y I e C - e-9, t 4 ? b 4 N I by o -a r., v e s M I o* b c s 'c.fO' O b f O c 7 9 3 L' C 9 p 0C %) Q g a < .o. t. 4 O' 4 4 G Q -r-t' U

• s O Q

% e e @C c.,.5 q s' s - c. p e c. = e o

n. -

~/ 3 C .. x 5 c , c-r-5 w C ($ vA >'T 3 .>c av z,6 f. I ~ *

• Y-l ar c u "70 Cy c>

l C. i e 3 Q. O@ f3C0 4 7g I u o V 2 W u 7 eT. 3 4 4HO Z (g O C~ t l ___m / ~ .2 C. e 3 i O.d O g .p-s.1 y.. 1 3 ~b h w w. g.: 4 0 (. p u I l i 4 i wi Cd C NO = 6 8 W =

O w:

s e u

=

C =- = c e =6 C6 c TJ C O-I LEb C U >'g [ de

== w-= - 20 We =- = 48 c V. - /. - C T f%

1. . 1

• d

>I c,. N = ": 4 f%# -a =

== T.: 0 5-=

== 5 *= E A

==

• d O:

.I e ,O as ! ;,e

4

6.==

st e o,a w oo ac cl d et a ->- a

. tw

\\r.:r ! e o n.E zef .e e- .4 > b E /= A,l A ~J o Go 204 K- "a = 0 b 4 F 0 O b e was <t l' <== E =-e u:

Cb e > + gee C>

6. e e ;: o gL -4 <bD L b C' t. <J <OO 6-l TC C 3 4. et e LJ .O. L =l w en 6 . n :> o e e-E. o w: e a 3 es .e C 4 m .D, e er ; -m4 g a

.6 C

e.g 3-U = = 3 l s: : : 4 C G ' 45 C 34 6 0 i G. f b

.dem

/. E 5 b 04 O l 0 p .A

== A at c OC h, "cl ' '. :.1 E 0 C= T b LJ O L.F: .t at ; eN 4 t*d 6.. C =* b .t===

• =

ab = = %= = = cu w,, s. 3 - -g e m - d -l: -a p 6e L T,,,; e - e 8 e*.-= c ;: S ee. A La= ci= b I 2' ) 0 -.\\ c -g -. e :::c = : -e 0; -L:

=a -

3C T > > 3: - : ) = > Zit O ste s tm go a = - - = b #'8

== d'B ".e 4= t

• t

": = a : ** 4 "L "" I/* 5 '" i #6 : 't U >*)\\>; =NZ .=

h => Je et =<a

- =

l -n N P* N w I '\\ 8 s i I i \\ \\ ~ o I \\ .o e I .= ; e / 4, b O-a I f%. l /

• s 3

..3 3,

• ).

O 0 4 .J. .A f.

• d N

'\\ ..N

• 4 U

== = ( a. m N N ? h. N . A e e e e e s g< e a e e e e e .9 .~ 4 = O =k .. k r s.* ~ .% k n s

es r H

e. -.o

4 O t, s h .e O =

L L

\\ E b N s.- N T.= Qy

• n k

Q -U k h 5 4 %N N \\. s w d g b 19 I b A ~ q CC M C D C - P. % C% D

• g oho L-7

\\ LO= g V7L s 7 A N 41 4 h N g 7 e De w a o= t l =: 4 b O as 4

== h 4 2 d b es g e4 y g .e p = y = 6. 3 = d d O - T .s -= st L 7 4 d V C C C O 2 A ,'.4= C = 2 2 7 D 4 o f:. =d 6 L b o e C = e p .e t T = * - es is es

== ed =* 3 =8

O C

.a g E U t/3 % C D= = g =l3 D C 5 'O-- s.d .G. = e c 3 .e m a 6 4 U

• C

.d d C = * * * & s CP ec 6 -= ** Ob h Cb M =s e u= = Je A >V L 4

=

2 mt n l L 3 2 e* _A C C a a = c.: g; e .e 4 4-d Is = 2 r= = = t-O e4 = g 3 ee y .e = 1 3 '.[. w= y =. 6

=.

= 60 = I

= y

== == = O e= TA:

1. K C

2 c .h..=. = =- = .4 e

• * =

D d e en we e a e 2 C- .= u O L .C E: ad &O L C. O = 0. U k = 6 L .s -e G: rs ( D .= 2 -2 t =3 -O

== a a s

• =

== E h

• 2 b=

= L L E g A O E 's o =e w et = t 'O L 3 M0-0= s s 6d : e. O"'. 2 ,a'( 's edZ = 3% O O s< ur o-e C* c =C O =

== ew =( g.e :. [. 'A c d Q .e

== e s = % ss ;e

==,,=g e e e en a e e !A e e e e e t/s A t* "O %'t A E A A A s" .i T E E E E .Ts C

• =

G E E

• I E

e e A- / i

a. I l n Y 6 g i 9 t l 1 ~ h 'b N l l k N ,b -5 } G f g) 5 N. E RI. ~ q i t T N i l N I 7 e Rt v l t b C C n T O k S 'q 5 -C 3 3 g C o 1 \\v \\ w t I \\ D ae. O = *. bI 1' C > 2 3p Q

• (

C h N - i s .e 3

==- M-L T 9 b \\ W Q 4 4 y nI lk 9 D t. Q 3. !.a .- Q (.** > =. ] j\\ W I,O - a

f%

f tb t e< Ei '. I V ( ,.3 j ). .I v./ a s g L d b

~

= c

== 3 m - e d = - .8 9 d C/

• et 4

3 = .= "C

• O O

at et O e e - ~ = e e i =

== 't 4 1 3-0 = => d 6 =. s o t .e ). 6 A i 6 b I' $ . C t 5 at .8 C 3 = <? 4 w e G -l 3 ,f u a

I e.

e\\ o s u x-a >l 3 2 ari -p = d 4 - i' = y Q

== 0 b .m f E E I a a s r: c e gp 4 . m E! 7 m h b ch w e c .4 -.* a= c = c. u6 = = /u =

c

a st\\ =d = : .e 3. .s. O C.. Ce y .a= 0 .s b l O M e-

== O- $D M = / meel Ei b = '\\? e EC e e 'e

e. 3 d

a 0 0-a O tt CC U c .d 1

== =* = 'I-3 -== ( 13 < g < g 0 >=

- > u >

. = e e a a -= = = = /. = =< = x m w 1,' = -s-l N = n .3 .e j / .4 ss c-r: ?. m .=. b aA =: +

= *

h B - < f ** = 4. 'm C c c, .e e tt = a c c c, p.o e e, ~ c: e e e-c e e .1 A a .s a

• :s s

.e .e M e er e

• a en M

,D c .z = r e, e-e - r a: .c C .-r. T

F

== / L

s s , c <A ND I 'O

• s c%

ao o s ss h t E ~> tg - 6 't 1w C 0 s o e i ~ s E z 4 C g N Sns = s,. t') t Q c e - tr 0 m s2 5 4.. h %a .= s. .e. R,, 4 sa L' g I c i 11 i o = ' ;. s. e (, 4, s s. N' q ~ 2, s '" 1 - I h. ,. = > i, s>s ,s s i s c C

s.,

( s i ' s, ~g 2 N s 4:, C i d '.% i s ,. c l t .e ~ o

== <v ti' 3 b 6, N. (= I s. s x T1, 4 &) S: s i 1 a s es, i I u. - e..:- L s% i ) q x si s i% w e. - n H hb =3 1 . < '(,

q o

2E t 4 sI 4 N.. s.. (

• A 6'

i Li h c s(: g g 's e. 53, is g t, te h i

• 0

'J 3 4* e 1 8 l S I *%. W 45 ? g i 43. $e j b d s's S ggI % i T f k'Y D i O k (- i I" i j l l d.: i <E 65 1 /. ! -l.Me 6 VI c cc _ l I i i 1 i -l g l w I O h b b ]t g x i e V s. e l i 9 e In =* 3 s a j 'l: u a r. s a s. ,t \\ a m = gs = g= w w C g e -e d C g. c

. e

). o a ,p,,t = .3 12 ,a j x. o 1, =: .= e ~* =- a S s c un o a c s. e s. c w -= O\\ s u -u s. s c= w a l *= J C C ** .U.

• =.
• L3 m

a = ,x \\ / UO D-

1. M a

e N cc : =w u e >= - L= iy a a -f-2 /s O' e --a e e o-o s-s c. *:

7..:- -

5. u /N. c. e== c. -a -= i S /

s

=w- = = c :- \\ = a.. e. s- <r. EE b 1 h [ / ~ ~ 2. f .'N s =s s w 2 ,ue ' k..b. 3, s <c n

6. * - -

7, ) c g

e

=- = e, - =< a w e , w .= s

a. w, 7

c, 2": .s

= :r G Q b t'.s f s. h f b

b i, e F Es

~;

p

O 4 4 4 g-M T I d i d ,( 4 o s M ta 3 N O N t, N e E t E Q N 7 d k .= r t, l -w s 9 \\ "J t

== 4 s g x h = o N ~ g = l 0 W s N e N ! b C D e s 4 r =

• L

( tr* 3 i I h s-9 S

4

'o e c. k g = *. ll b 4 I *n Qs h she 'N; N Q f g. ~.t h I W i = > N

~

L M-s e. s. a m 4 )4 t Q L Q '. .L u e s s -(.: ~ 5 )a n ~ Q 9 A Q k >) q( h. 1 2 ' s O u~- n 2_,**., 5 c-0 1 -,s [.! h Ei l M I x-E7 .f n' -8 c. 3 5 'y; 34 i u a.. c a j 3 A g, e O N I 5 j o'N = Y s,. .u i% 2 = .u = v i Ua m- =

• =

= Q = y != = c = o = =

== 0 . = =. c. o

.: w>

i. A s

o E

0: : w w ee e-es e/

=.L.

= h c h e. t .c Oe = = - w w e :. A .* e.s -h L a u e

• O

- so C en - 4 .: e.y T E.m .e g e C< 6 6-o 3,= =: * - /E : : J :- : e s: E ='S h e u w u -e w.w. => - T =r, c-n = de

e

6. e e.

a= w : a =2

-.

c >. t.a-

: : :: : s c

=

<> 8 ec A AC "4 C 4>

t h 9 I D h. ,d 4T ~ I. =j D t e.q .e = wd ca ,= ~ s, N b d d d E N 8 y 'J C (. e e e e g ".8 a e t a.f .n e a o8. s. O n, vi i o

r4 -b

== W $ l E e a e e e e

• 3

67 o MMk INTEROOFFICE MEMO To: Distribution March 20, 1985 FROM: G.R. Purdy

SUBJECT:

CPSES, 35-1195 Unit 2 Component Support Reinspection Program Implementation. It is anticipated that all Engineering and QA action that is required to sup the inspection / reinspection of Unit 2 pipe hangers will be completed by 4/12/85 port To achieve this completion date, QA plans to distribute the proposed revision to QI-QAP-II.1-28, for review and comment, to the normal distribution for review, during the week of 3/25/85. In addition comments will also be associated with the TRT and IPC efforts as it is obiviously necessary to issue a requested from personnel program which will not be subject to numerous f uture revisions. ( Approximately 2 weeks has been allocated to the instruction review resolution process. comment and Maintaining this objective is critical, training in the revised instruction will begin the week of 4/8/85since QC inspector i Assuming that QC training and Engineering revision of the componant specification (=) detail drawing icsaance and genecie inspection / reinspection of Unit 2 pipe hangers on 4/15/85is completed by 4/ The applicable Engineering, Construction, QA, and Start-up Programs have all b revised to require that prior to ASME Code pressure testing, all piping, components een and supports in the applicable stress problem boundary will be completed and accep by QA and the ANI. to assure that Start-up Turnovers, Stress Problems, and Pressure Te ? were properly integrated and defined; this program went to the extent of identif i es each ISO, and each support by HITS correlation, that was involved in each of the y ng stress problems. [ Accordingly, Start-up Turnovers, Stress Problems, Pressure Tests, 1 and N-5 Subsystems became synonymous, and Engineering, Building Management, QA priorities became obvious based on the start-up turnover schedule. j and The above paragraph does not preclude however, transferring operational custody of an ASME component, subsystem, or system to Start-up (i.e., for the purpose of j prerequisite testing) prior to Code pressure testing and N-5 certification. f only constraints placed on Start-up testing prior to N-5 certification are: The 1. All physical work done on an ASME component, subsystem, or system which is not N-5 certified with the NA-Symbol stamp applied, will be done in accordance with the ASME QA Program; and, k 2. Code pressure testing will not be conducted until a subsystem is complete accepted by QA and the ANI, ance of the pressure test. and is capable of N-5 certification upon accept-m

~ .. I, As system completion is in reality based on Engineering design and design r I conciliation, and Building Management construction completion, QA priorities e-with respect to implementing the pipe support lished by Building Management. inspection program must be estab-Similarly, when a subsystem is ready for pres-sure testing and N-5 certification is actually determined by Engineering design reconciliation and the Building Management construction completion schedule. Programmatically however, the prerequisites to ASME pressure testing are: 1. 79-14 stress analysis complete; 2. "N-5 Iasue" BHP's have been issued for all ISO's within the subsystem; 3. VCD/DRD's have been issued for all supports in the subsystem; 4. The as-constructed condition of all items / components in the subsystem have been reconciled with the design; 5. All fabrication and installation associated with the subsystem has been accepted by QA and the ANI; and, 6. The "Prepressure Test /N-5 Walkdown" has been conducted by QC, deficiencies resolved, which includes the joint Engineering /QC Walkdown with all, of 100% of the subsystem supports to: a) Verify all items are f ree of damage and unauthorized work; b) verify that all hardware is properly installed; and c) Verify and record all design specified variables such as clearances, angularity, snubber A-C and C-C dimen-sions, etc. Accordingly, a litle re-engineering on the Building Management System completion logic is required to accomodate the prerequisites proposed ASME ing prerogative and not a QA requirement.when the prerequisites are comple i , however, ) s91 rr<k,- G.R. Purdy 8 Site QA Manager GRP/pw Distribution: J.T. Merritt D. Westbrook P.E. Halstead J. Burgess D.C. Frankum H.R. Deem L.M. Popplewell G. Smith M.R. McBay P. Lyendecker (IPC) G.B. Crane C. Moholman (CPRT) F.L. Powers T. Blixt J. Ruimerman R. Siever I ( ) I, ,,n J

Evanation Resealth Corp 01~dtion OFFICE MEMORANDUM QA/QC-RT-076 TO: J. Hansel FROM: M. Solon DATE: April 8, 1985

SUBJECT:

Valve Disassembly, Issue VII.b.2 Generic Valve Evaluation Sum =ary Documentation (i.e. specifications, vendor instruction manuals and drawings) were reviewed to determine which generic valve types required disassembly prior to welded installation into the piping systems. It is concluded that diaphragm valves, manufactured by ITT-Grinnell, are the only valves which required disassembly prior to weldup. Purchase orders CP-0020A, 0020B, 0604 and 0001 (S.O.0220) contain nuclear safety related (Q) diaphragm valves with the potential for mismatching valve bodies and internals when the valves were reassembled. The number of valves in these purchase orders is apprcximately 600 total for Units 1, 2 and Common. Non-Q diaphragm valves contained in purchase orders CP-0021B.1, 0021D and 0604 are identical in form and fit to the Q valves, and will be considered as a source for rismatching internals and valve bodies. Discussion In accordance with the Action Plan, para. 4.1.1, an evaluation was made to determine the generic valve types that require disassembly and removal of l internals prior to welding. Project specifications, drawings and vendor j instruction manuals were reviewed. The latest specification index pages l containing valves were marked up, and Table 1 was prepared to su=marize the results of the documentation review. All Q valve types were reviewed first. For those valve types that were found to require disassembly, similar non-Q valve types were evaluated as a possible source for mismatching non-Q internals with Q valve bodies. Valves supplied with vendor packaged equipment were not reviewed. Specific discussion of all valve types, by specification, follows. f Referring to Table 1, Page 1: I (1) The vendor instruction manuals for the diaphragm valves (MS-20A, 20B) l require that the bonnet assembly be removed to protect the diaphragm during veldup into the piping system. I (2) The vendor instruction manuals for the bulk valve orders (MS-20A.1, 20.B.1, 20.B.2) do not require valve disassembly for welded i installation into the piping system. r;/ M i 3y~ t ~ 4 l 800 0ak Rid &hrnjike Sdn50A (6WhrggaSgmpxmAnumsta.sma 7 i

QA/QC-RT-076 Page 2 April 8, 1985 (3) The specification for the rubber lined check valves (MS-208.3) has only four 24 inch valves. These valves, which are in the service water system, are all valve type 24CC302WA, Notes 3, 39 and are identical. Therefore, there is no need for further evaluation of potential mismatch. (4) Butterfly / wafer disc valves use bolted installation exclusively. Referring to Table 1, Page 2: (1) The non-Q diaphragm (MS-21B.1, 21D) require valve disassembly for veldup. They are identical in form and fit to the Q diaphragm valves, and will therefore, be considered a potential discrepancy source for the Q valves. (2) The remaining non-Q valves (MS-21A, 21B, 21C, 21D.2, 21E) have no Q valve counterpart that requires disassembly; and therefore, they were not reviewed. Referring to Table 1, Page 3: (1) No review is required for tha non-Q circulating water valves (MS-75). Referring to Table 1, Page 4: (1) The main steam valves (MS-76, 77, 78, 79) are special valves and therefore were not reviewed. (2) Review of the specifications and vendor instruction manuals for the butterfly deluge valves and the HVAC containment isolation valves (MS-82.1, 86) showed the valve installations to be bolted. Referring to Table 1, Page 5: (1) Review of the Q and non-Q control valves (MS-600, 601) shows that where soft seats are used, the internals must be removed prior to welded installation. Specification MS-600 (Q valves) has only four valves with soft seats. These valves (HV-4710, 4711, Data Sheets A0-19) are identical 4 inch 150 psi carbon steel globe valves. Specification MS-601 (non-Q) does not contain non-Q valves of similar configuration. Therefore, mismatch of valve internals and bodies need not be considered. (2) The vendor instruction manual for the process solenoid valves (MS-603) does not require valve disassembly. ]

i ~~ F QA/QC-RT-076 Page 3 April 8, 1985 t (3) The instruction manual for the power operated diaphragm valves (MS-604) requires valve disassembly before welded installation. The specification contains four Q valves. These are identical 150 psi 4 inch stainless steel valves (Tag No. HV-5157, 5158, Data Sheets A2-12,- 13). Specification MS-604 contains 1, 2 and 3 inch air operated non-Q valves. These valves, Q and non-Q, are similar dimensionally to the air operated Q diaphragm valves in the NSSS purchase order, CP-0001 (S.O.0220). Therefore, there is a potential for mismatching parts. Referring-to Table 1. Page 6: (1) The non-Q automatic pump recirculation valves (MS-627) need not be -reviewed. (2) Por the specification for the pilot solenoid valves (MS-632), the valve ends are threaded. (3) Tye NSSS purchase order CP-0001 (Shop Order 0220) contains valves l supplied by Rockwell, Fisher, Velan, Copes Vulcan, Crosby, . Westinghouse and ITT-Grinnell. Vendor drawings and it.struction manuals were reviewed to reach the following conclusions: (a) The Crosby valves are safety and relief valves, and are not considered. a (b) The Rockwell, fisher, Velan valves have metal seats and do not require disassembly before weldup. (c) Some Copes Vulcan valves have non-metallic seats. However, the instruction manual does not require valve disassembly before weldup. (d) The ITT-Grinnell valves include 3 and 4 inch manual Q valves, J similar dimensionally to those in MS-20B; and air operated Q valves from 3/4 inch to 4 inch, of which the 1, 2, 3, 4 inch valves are similar dimensionally to those in MS-604. Therefore, these valves, with the possible exception of the 3/4 inch valves, will be added to the population of valves with the potential for having mismatched parts. Further review and evaluation is required to better define the sub populations, taking-into consideration the characteristics of the valve topworks. This effort will be limited to the ITT-Grinnell valves in purchase orders CP-020A, 020B,'0604 and 0001 (S.O. 0220). _j 800 Oak Ridgeihrnpike Suite 301 Oak Ridge. Tennessee 37830 (615) 482 79 3 j

QA/QC-RT-076 Page 4 April 8, 1985 $11&L / M. Solon / cc: D. Alexander V. Hoffman P. E. Ortstadt File VII.b.2.4B MS/si' 2 800 Oak Ridge ihrnpike Suite 501 Oak Ridse Tenrmm2M EUEGEMU lf m

e 4 Evination Resg1 0FFICE MEMORANDUM QA/QC-RT-090 TO: J. L. Hansel FROM: M. Solon DATE: May 2, 1985

SUBJECT:

Valve Disassembly, Issue VII.b.2 Additional Generic Valve Evaluation

References:

(1) 02fice Memorandum, M. Solon to J. Hansel, " Generic Valve Evaluation", dated 04/08/85 (2) SDAR CP-83-01, Corrective Action for Borg-Warner Check Valves (3) Telecon, M. Solon to P. Milinazzo, " Disassembly and Reassembly of Borg-Warner Check Valves", dated 04/22/85 Summary Reference 1 evaluated the generic valve types which required disassembly prior to welded installation into the piping system. The objective of this further evaluation is to determine if there are generic valve types which required disassembly and subsequent reassembly after the valves were delivered to the site. It vss det :rnined that altheu h many cypes of valves were disecsc: bled and s reassembled for purge, flush, test and repair, there was only one generic valve type (in addition to those in Ref. 1) which required disassembly. These were check valves supplied by the Borg-Warner Nuclear Valve Division (B-W), under P.O. No. CP-0020B.1. There are approximately 160 valves, total for Units 1, 2 and Common, which fall into this generic type valve category. It was concluded that of this total only some of the low pressure (150 and 300 psi) valves could be reassembled with an incorrect body / bonnet generic configuration. All valves in question are ASME III, Code Class 2, and therefore, code classification violations could not have occurred. Discussion B-W check valves were found to have possible design and manufacturing deficiencies (Reference 2), which required that the valves already en site be disassembled for inspection and repair if required. Review of the B-W check valve drawings, with confirmation by the vendor (Reference 3) resulted in the conclusion that valve bodies and bonnets of the same size and pressure rating could have been reassembled, regardless of ASME III Code Class (Class 2, 3) or material (carbon, stainless steel). However, per the specification (MS-20-B.1, paragraph 3.3.3) the valves were all supplied as Class 2. JJLL. h. 2 ~ 0$ 800 0.tk Ridge Thrnpike Suite 501 Oak Ridge, Tennessee 37830 (615) 482 7973 C-5

o QA/QC-RT-088 Page 2 May 2, 1985 A matrix of B-W check valve types is given in Table 1. All valves are ASME III. Code Class 2. Valve types which have the same body / bonnet fit-up are circled. The valves which could be reassembled with incorrect bonnet and internals are as follows: 3 inch /150 psi (carbon and stainless steel) 4 inch /150 psi (carbon and stainless steel) 10 inch /150 psi (CS and SS) and 300 psi (CS) There are approximately 70 valves falling into these categories. Valves which were disassembled, other than those defined herein and in Reference 1, will be identified by reviewing operations travelers. Y M. Solon / cc: D. Alexander V. Hoffman P. Ortstadt ERC File File VII.b.2-4B File VII.b.2-9 MS/sl Attachments 800 Oak Ridge'lbrnpike Suite 501 Oak Ridge, Tennessee 37830 (615) 482 7973

7464E / Bsee;.kipeneg Cm ex Vni.es 7y' per AMS1 Peess s ass e n disscu G inca Bincu /0 n cu 16 i en i R nna q !S S lSS CS CS C Sls s /SO PC) . X^~>A _ ss 360 Ps/ i SS ~ 9o0 psi CS CS CS CS T Wort.S: 0) Au Vai st-c ees AfNd.?27, l's b e Cut s r 2. (2) SS= Srsim. es.c srn Bsey / Bonosr CS= C a te s o a Src Ea by.y' Boss atr (3) = Samt VGw s Bob y /Bo n n er F}rrup gg M s/"f/85

I' E-/anation .ttesearch Corporation 0FFICE MEMORANDUM QA/QC-RT-103 TO: J. L. Hansel FROM: M. Solon DATE: May 20, 1985

SUBJECT:

Valve Disassembly, Issue VII,b.2, Generic Safety Consequences Analysis

REFERENCES:

1. Mc=orandum QA/QC-RT-076, " Valve Disassembly, Issue VII.b.2 Generic Valve Evaluation," April 8, 1985

2. Memorandum QA/QC-RT-090, " Valve Disassembly, Issue VII.b.2 Additional Generic Valve Evaluation," May 2, 1985 J. Telecon, M. Solon and B. Borst (ITT-Grinnell), April 9, 1985

4. Telecon, M. Solon and B. Borst (ITT-Grinnell, May 15, 1985

,5. Telecon, M. Solon and P. M111nazzo (Borg-Warner), April 22, 1985

SUMMARY

The generic valve types that required disassembly and reassembly were identified in Lietences I and 2. The safety implications resulting from reassembly of incorrect valve components were evaluated, and are summarized as follows: 1. Manual and air operated ITT-Grinnell diaphragm valves (except the 3/4 inch, stainless steel, Class 3, air operated valves), if reassembled with incorrect bonnet assemblies, could result in significant safety implications rang'.ng from violation of the ASME III code

• to failure of the valve.

2. The following Borg-Warner sving check valves, if reassembled with incorrect bonnet assemblies, could result in corrosion problems, potential failure of the bonnet and/or loss of function of the valve: a. Three and four inch /150 psi valves b. Ten inch /150 psi and 300 psi valves The combination of valve bodies and bonnet assemblies which can be bolted up are shown in Table 1 (manual diaphragm valves), Table 2 (air-operated diaphragm valves) and Table 3 (Borg-Warner check valves). 'Ihe potential generic safety consequences of incorrectly reassembled valves are summarized in Table 4.

• Code violation herein loosely defined as an ASME valve reassembled with a bonnet assembly from a lower ASME class valve.

.M.L.2I 6B -(L-- 800 0au aiazeiuru+ uite soi n,,u m, m,-.. v o,n oo c,2c, a

QA/QC-RT-103 Page 2 May 20, 1985 Valves which do not fall into'the generic categories defined in References 1 and 2 will be treated on a case by case basis. Since there are many different valve types which were disassembled for test, repair,-flush, etc., generic evaluations prior to defining the population are not practical. A recommended approach is given in Section 3 of Discussion. Discussion In accordance with the Action Plan, paragraph 4.1.3, an evaluation was made to determine the consequences of reassembling incorrect bonnet assemblies on valves which required disassembly. The two generic types of valves identified in References 1 and 2 were evaluated and are discussed below. 1. ITT-Grinnell Diaphragm Valves The ITT-Grinnell diaphragm valves were supplied under the following purchase orders: Purchase Order, CP-Description 0020A ASME III, Manual, 2 Inch and Smaller 4 0020B ASME III, Manual, 3 and 4 Inches i 0604 ASME III and Non-ASME, Power Operated 0001. AEME III', Mar.ual and Power Operat'ed 0021B.1 Non-ASME, Manual, 2 Inch and Smaller l 0021D Non-ASME, Manual, 3 and 4 Inches j I Based on References 1, 3 and 4, the following conclusions were drawn regarding possible reassembly configuration errors and resulting differences in valve construction: ~ l a. Valves of the same size have the same body / bonnet fit-up, regardless of ASME III Class (including non-ASME), material and i pressure rating. I b. Bonnet material is stainless steel regardless of body material (Stainless Steel or Carbon Steel). c. Bonnet wall thickness depends on valve size only, and is the same j for 150 psi and 300 psi ratings. d. Diaphragm thickness depends on valve size only, and is the same i-for 150 psi and 300 psi ratinga. However 300 pai, 2 inch, 3 inch and 4 inch valves have a diaphragm support cushion. } e. Two, three and four inch, 300 psi manual valves use a brass spindle; whereas the 150 psi valves and the 300 psi air operated valves use a stainless steel spindle. All other internals are of the same materials, ssysurwwnsuwe 1

QA/QC-RT-103 Page 3 May 20, 1985 The following additional information was obtained from the valve drawings. f. Operator action (air to open or close) was determined and is summarized in Table 2. Except for the 4 inch valves, all the valve operators with the same action were the same size for a given valve size. g. The 4 inch Class 2 valves have a larger actuator than the 4 inch Class 3 valves. It.is presumed that reassembly of a manual valve with a bonnet assembly having an air operator, or vice versa, is not credible. Such an error would be obvious, both visually and during preop testing. The evaluation was performed for the highest level of valve (be it ASME Class, pressure rating or material), assuming reassembly with a bonnet from a valve of lower level. In addition, valve operator action and size was considered. The possible reassembly errors were obtained from Table 1 (manual valves) and Table 2 (air operated valves) wherein the number of ASME valves, broken down by class, pressure rating and material, are shown for each valve size. The various types of non-ASME valves are also shown in the tables. Except for the 3/4 inch and 4 inch air operated valves, non-ASME valve bonnets could be installed on the ASME valves. A summary of the evaluation is given in Table 4, Items 1 through 10B. Except for the 3/4 inch, Class 3, 300 psi, stainless steel valves (Item 7B), reassembly with an incorrect bonnet assembly could result in a code violation and/or potential valve failure or loss of function. 2. Borg-Warner Swtig Check Valves The Borg-Warner swing check valves were supplied as part of purchase order CP-0020B.1. Based on References 2 and 5, the following conclusions were drawn regarding possible reassembly configuration errors and resulting differences in valve construction: a. Except for the 10 inch valves, only valves of the same size and pressu,re rating have the same valve body / bonnet fit-up. b. Ten inch valves have the same body / bonnet fit-up for 150 psi and 300 psi. c. Carbon steel valves have carbon steel bodies, seats and bonnets. Stainless steel valves have stainless steel bodies, seats and bonnets. d. Except for the 10 inch carbon steel valves, all valves have stainless steel disks. The 10 inch carbon steel valves have carbon steel disks. J

QA/QC-RT-103 Page 4 May 20, 1985 All valves were provided as Class 2, regardless of class specified. 4 e. The possible reassembly errors were determined-from Table 3, wherein the number of valves in each assembleable category is given. Only the 3 and 4 inch 150 psi valves and the 10 inch valves could be reassembled with body / bonnet errors with potential safety significance. A summary of the analysis is given in Table 4, Items 11 through 13. In each of these cases, reassembly errors could result in valve failure or loss of function. 3. Other Valve Types Dis / Reassembled Analysis of the generic valves for safety consequences is practical only for the ITT-Grinnell diaphragm valves and Borg-Warner check valves. These valves were known to have required dis / reassembly of all the valves. This type of analysis for the remaining valves that were dis / reassembled for repair, test, flush, etc. should be done on a case by case basis. The recommended approach would be to include all the other valves

• in the population. When a valve is selected as a sample, the documentation should be reviewed to determine if adverse effects could result from errors in reassembly.

If no adverse effects are identified, the valve should be discarded from the sample, and another selected. If the evaluation is not conclusive, the valve should remain in the sarple, and the evaluation would take place after the valve is inspected, if discrepancies are found. JNbI Its M. Solon cc: D. Alexander V. Hoffman P. E. Ortstadt File VII.b.2-9 File VII.b.2-49 ERC File MS/sl

• Other screening criteria, e.g. short time span between disassembly and reassembly, may be considered to eliminate valves from the population.

l l 800 Oak Rite Thruda Sui %M J

dS SS cs SS //74e u et 41,cuo /N 3l$ " 'v n N.' op /" y in y D / h h h h 1 ISO 8 /SO # 30 6 /9 /7 y ll do re t (7YP) 3 r9 e /2 sco r \\ t i CC i CC /U.-} AJ G /} L. l /) ! )sj t. -?L .n,/ 3" 2" 'v in s\\ ny N b< b 6 h/ &y S /5C # //6 * // 9't/ /Sc# / 7 27 i i ?^C Y2, jf,', 2$ /D$ t C$ .S 5 /r?An u n e. 6n-4:mE /UfoudL 9" 'V q ',y /k R,[y/v./ 'o,/ s [.- [a e c y/s y/& = a e n A A /SO W /0 26 ,o o u o .J w s s

• w q

300 4 L 5 e o e Ml %o x. w q y c h N s s i Wort : i. s/wiae or 14u es.s

Ge'u /

/?/ritjus :_ biApHHfdat Y44 yi S

3/4 - 3 0 0.f s / / "- 3 9 0 P:! Asti O sn reb - A TO /h?e dru,ereb - A 7' O p C 5 -cL 2 5 5-CL 5 C S -CL 3 SS y // art ,g / CL 2 CL?- l'ryP) / 3 I l z * - E o o psi ~ 3 " - s r. Sri. A/4 Cf tim rt b kNz 0pcp,+r gb .Cr. Crl-C L. 2 CL 3 C t. z. CL3 aTo Aro ATc ATO A TO A7~C. /50 psi 1I 7 3cro psi 3 /h !/ $ " - Sr. Src. N'2n-ASAlf / /} Al O P f f A TE b /),}; O g g,s g 3p k 7~O f S r. .Srt. dl2 CL 3 s -u i, / 1.,, l 0 ATO A TO A TC /SO /SO /SO 3 ro psi Psi ps/ ps i /SO f31 Y i ~ 007:l l 2- / 7~MLZ 2 l /?bt Ortsw0 basPit/Apr Vus IVsit : /. //unme or VAwtS Z. A ~d= eit;.ro cpen 0TC = Atti r0 ClosE

F' h - I h 6 e f* es cs 5s cs ss //or6/. ^loway ^ /9 Wod i /f g "3 (rys) 'l " - /Sorsi ./ ". <yo o ps, cs ss cs ss /0 3 z/ 6"- /50 psi f 7oo pgl ~~ CS SS CS SS 8 ze $Y m yQ 3} me CC cc cc -e T48tf 3 .u i Bonn-Ala m 4 b 2 Ge.e Mn ves f ~~ 3* cs I rs cs ss iv ' z y <* C / ![ s": /

4 L TABLE 4 GRERIC SAFETY CONSEQUENCES ANALYSIS Page 1 ITEM DESCRIPTICM SAFETY PRES 5URE POTENTIAL POTENTIAL CLASS RATING REASSEMBLY ERROR FAILURE & EFFECTS i t i ITT-Grinnell I Diaphragm Valve 3 300pst 1. Bonnet assembly from C.S. 1. No failure. All bonnets are St. St. with internals ) Manual valve of same materials. 3/4 inch Stainless Steel 2. Bonnet asse ely from 150 psi 2. No failure. The bonnet and diaphragm thicknesses are t e . valve same for 150 pst and 300 pst valves. 3. Bonnet esse dly from non-ASME 3. a. Potental failure during a seismic event. Loss of l valve function. leakage. l b. Code violation. i l2 l ITT-Grinnell 150 pst 1. Bonnet asse d ly from non-ASME 1. a. Potenttal failure during a seismic event. Loss of 2 Otaphrage Valve valve function. leakage. Manual + l 3/4 inch 2. Bonnet assed ly from ASME !!!. b. Code violation. l Carbon Steel Class 3 valve 2. Code violation. ITT-Grinnell 3 . Otaphragm Valve

2 l 150 1.

Bonnet assee ly from C.S. 1. No failure. All bonnets are St. St. with internals of jnanual valve same materials.

• I inch Statniess Steel j

2. Bonnet assedly from non-ASME 2. a. Potential failure during a seismic event. Loss of i I valve function leakage. I 3. Bonnet sisedly ASME Ill. Class 3' 3. Code violation. valve i N E

r s-0 i e s TABLE 4 (Cont'd) GENERIC SAFETY CONSEOUENCES ANALYSIS (Cont'd) Pane 2 SAFETf PRESSURE POTENTIAL POTENTIAL ITEM DESCRIPTIO* CLASS RATING REASSEMBLY ERROR FAILURE ITT-Grinnell Diaphrage 3 300

1. Connet assembly from C.S.

1. No failure. All bonnets are St. St. with in.

4 valve Manual 2 inch Valve. ternals of same materials. Stainless Steel.

2. Bonnet assembly from 150 2.a. Galling of St. St. spindle (300 pst valve I

psi valve. spindle is brass). Jaming of 6alve.

b. No support cushion. Failure of diaphraqm

& leakage. j j

3. Bonnet assembly from non-3.a. Potential failure during a seismic event.

ASME Valve. Loss of function leakane.

b. Code violation, j

i 1 5 ITT-Grinnell Diaphragm 2 150

1. Bonnet assembly frem C.S.

1. No failure. All bonnets are St. St. with in-l l

Valve Manual 2 inch Valve. ternals of same materials. l 5tainless Steel.

2. Bonnet assembly from non-2.a. Potential failure during a seismic event.

ASME valve. Loss of function & leakage. I l

b. Code violation.

t.

3. Bonnet assembly from ASHE

3. Code violation.

I III. Class 3 valve. ITT-Grine11 Diaphragm 2 300

1. Bonnet assembly from C.S.

1. No failure. All bonnets are St. St..with in-6 i

Valve Manual 3 inch & Valve. ternals of same materials. I 4 inch Stainless Steel.

2. Bonnet assembly from 150 2.a. Galling of St. St. spindle (300 pst valve psi valve.

spindle is brass). Jamina of valve. i

b. No support cushion. Failure of diaphraam l

I & leakage. a l

3. Bonnet assembly from non-3.a. Potential failure during a seismic event.

A5ftE Valve. Loss of function % leakage.

b. Code violation.

5

4. Bonnet assembly from A511E

4. Code violation.

111. Class 3 valve. t i* e I L--

f .i TABLE 4 (CONT *0) GENERIC $AFETY CONSEQUENCES ANALYSIS page 3 e ITIM DESCRIPTION 5AFETY PRESSURE POTENTIAL POTENTIAL CLASS RATING REASSEMBLY ERROR FAILURE 7A ITT-Grinnell 2 300 1. Bonnet and actuator 1.a. Code violation. Diaphragm Valve assembly.from Class b. No failure. Actuator action and size the same. I Air operated (ATO) 3 valve 3/4 inch j Carbon Steel 7B 5tainless Steel 3 300 1. Bonnet and actuator 1.a. No failure. All bonnets are St. St. with internals assembly from C.Stl.. of the same materfals. Actuator action and size it.e Class 2 valve same. 8A ITT-Grtnnell 2 300 1. Bonnet and actuator 1.a. Code violation Diaphragm Valve assembly f rom C. Stl.. b. No failure. All bonnets are St. St. with internals of Air operated ( ATO)- Class 3 valve the same materials. Actuator action and size the same. I inch 1 Stainless Steel i 2. Bonnet and actuator 2.a. Code violation. assembey from non-ASME. b. Potential fatture during a seismic event. Loss of 150 psi valve function & leakage. 88 3 300 1. Bonnet and actuator 1. Same as 2 above. assembly f rom non-ASME. 150 pst valve 9A ITT-Grinnell 2 300 1. Bonnet and actuator 1.a. Code violation. Diaphragm Valve assembly from Class 3 b. Incorrect actuator action and system operation. Air operated (ATO) valve with ATC actuator 2 inch and 3 inch Stainless Steel 2. Bonnet and actuator 2.a. Code violation. assembly from non-ASME. b. Potential failure during a seismec event. Loss of 150 pst valve function & leakage. 98 Air operated (ATC) 3 300 1. Bonnet and ATO actuator 1. Same as 2 above. assently from non.ASME. 150 pst valve 2. Incorrect actuator action and system operation, t 9 M

4..s e TABtf 4 (Cont'd) GENERIC SAFETY Con 5E00ErfES AMALYSIS (Cont'd) page 4 SAFETY PRESSURE POTENTIAL POTENTIAL ITEM CESCQiPTICN CLASS RATI% REASSEMGty ERDOR FAltuRE l 10 A ITT-Grinnell Diaphragm 2 150

1. Bonnet and actuator assembly 1.a. Code violation valve air operated (ATO) from class 3. ATO valve.

b. Smaller actuator; slower valve I

4 incn Stainless Steel openino & closina times I

2. Bonnet & actuator asserely 2.a. Code violation from class 3. ATC valve.

b. Incorrect actuator action and system operation.

10 B Air operated (ATC) 3 300

1. Bonnet and actuator assembly 1.a. Failure of bonnet seal and/or bonnat from class 2, 150 psi, ATO cover. External leakage.

valve.

b. Incorrect actuator action and system operation.

11 Borg.uarner swing check 2 150 psi

1. Bonnet assembly from C.S.

1.a. Corrosion and potential failure of valve M Stainless

valve, bonnet. Contanimation of system froa 3'M h Y #ACII3 #* #* #

corrosion products. n

b. Corrosion of C.S. seat. Loss of leak tightness & check valve function.

l Borg-Warner swing check 2 300 psi

1. Bonnet assembly fron 150

1. Failure of bonnet seal and/or bonnet l 12 valve 10 inch Stainless psi valve, cover. External leakage.

Steel. I

2. Bonnet assembly from C.S.

2.a. Corrosion of bonnet. Potential valve. failure of bonnet. Contamination j of system from corrosion products.

b. Corrosion of C.S. seat. Loss of leat i

tightness and check valve function.

c. Corrosion and failure of C.S. disk.

13 Borg. Warner swing check 2 150 pst

1. Bonnet assembly from C.S.

1.a. Corrosion and potential failure of valve 10 inch Stainless valve. bonnet. Contamination of system from corrosion products.

b. Corrosion of C.S. seat. Loss of leak tightness and check valve function.

c. Corrosion and failure of C.S. disk.

Rev. / 3l23lg g c

y*

• • #ALAJATION wsCEATCM CGW80WATION t

QA/QC-RT-149 TO: J. L. Hansel I FROM: J. N. Barger l DATE: June 19, 1985

SUBJECT:

Valve Disassembly, Issue VII b.2. Dis / Reassembly Procedural Control REhERENCE: Memorandum QA/QC-RT-106 Review of the construction and QA procedures have been completed. Based on the review it was found that construction procedure CP-CPM-9.18 Revision 0 and QA procedure QI-QAP 11.1-26 require positi.ve identification of parts for valves listed in supplements of CP-CPM-9.18. This function is controlled by QI-QAP 11.1-26 which requires the use of an approved, standard form, QC Checklist (QCV). The QCV lists inspection points for positive identification of valve parts which includes body, bonnet and disc heat numbers and, where prescribed the application of match marks for alignment purposes. Valves not addressed in supplements of CP-CPM-9.18 are dis / reassembled in accordance with construction operation travelers. These travelers are prepared in accordance with construction procedure CP-CPM-6.3 and further ceve :J in QA prece. lute Ql-QAt 11.1-26. CP-CPM-6.3 requires that the valve part, serial or tag number be recorded on the traveler prior to the start of valve disassembly. Additional positive information such as body, bonnet and disc heat numbers were included in some cases by personnel initiating the traveler, but was not required. Subsequent to issuing CP-CPM-9.18 and QI-QAP 11.1-26, positive identification of most valves were recorded prior to the start of valve disassembly. A number of valves have been dis / reassembled more than one time. Therefore, it is conceivable that a valve may have been dis / reassembled using the early procedures and again using the current procedures. Based on the forgoing it is concluded that valves reassembled using early procedures had more potential for reassembly errors than using the procedures now in effect. The significant difference being that the earlier procedures did not require recording the bonnet, body and disc heat number before disassembling the valve. The potential for reassembly error is considerably reduced for valves disassembled for the first time after the establishment of the QCV. 2:6.1 7, 0 - j (_g

7 e.- e O E WATION WEBEATC*A COWPOWATION The assessment made in the reference memorandum has changed due to the large percentage of valves dis / reassembled using early procedures and some valves currently not covered by QCV. Therefore, the subpopulation for Issue VII.b.2 vill not be made up of valves dis / reassembled using early procedures. The basis for the subpopulation will be finalized and reported in the near future. AM e A4 N.B/rger cc: D. J. Alexander M. Obert @ V. Hoffman FILE VII.b.2-4 File VII.b.2-9 / ERC File JNB/sp i l l l I l i [

TEXAS U"'ILITIES GENERATING C^MPANY cPPAi 45.530 OTflCE M EMOR A NDUM DISTRIBUTION Cien Rose. Teu, 7/22/85 suwen UNIT.2 ASME STARTUP ACTIVITIES All Unit 2 Startup Activities involving the disassembly / reassembly of ASME-components will require the issuance of work packages in accordance with CP-CPM 7.1. The following processes should be followed in order to expedite package prep-aration and processing. Startup should identify to the Unit 2 PFG all ASME components which require disassembly / reassembly as listed in the flush or hydro plans. Startup shall prepare the following documents and transmit them to PFG for preparation of the supplementary work packages. An IRN (Inspected Item Removal Notice) shall be prepared by Startup for each flanged ASME piping connection to be disassembled / reassembled. An IRN shall also be prepared by Startup for each generic valve identified in CP-CPt19.18 which requires disassembly / reassembly. All other valves not addressed in CP-CPM 9.18 as well as work items on other ASME equipment will require an operation traveler or startup work permit prepared by engineering or startup. Upon receipt of these documents, the PFG shall prepare the supplementary work packages in accordance with CP-CPM 7.1. The IRN's will be numbered by the PFG and the required inspection documents ( ill be added. Prior to issuance to Startup any required QC/ANI reviews will oe obtained by the PFG if not previously obtained by startup. Startup will be responsible for obtaining the QC notification signature on IRN's. Upon request by Startup the packages will be issued in accordance with rp cpl 17.1. Onen documantaticn will be tracked in tne WEC and PFM component track-ing data base flaintenance of the Master Data Base will remain in the respon-sibilty of Startup and the fl-5 group. f$ m M.R. McBay [lding Manager R.B.!! - Bui MRM/jgl DISTRIBUTION: C.E. Scott K.L. Luken ~ W.E. Baker H.A. Hutchinson G. Bunt G. Purdy

8. Siever

( F.L. Parters G.B. Crane W h'?-7.0-f pt)

l w LvE cI WEFECTlON CMECKL!$T ISSUE 3ZII.6.2 T/.G110. ITEM NO. GEil.SAMPLL 7 j 7ggg f/4 SUB. cat-IPLE O - RIR NO. /34-S VALVL M ARKlflGS: YES NO DODY C BONNET ACCESS. { ] DODY NO. E 349.3/ -6 BOtitIETT tlO. E 34 8 S TRA ' /- c lL i Y.' d ) neuass; sje ;9 isn-e-30 xave m* me-t g.e/ - 0 9* .i yv ~ 0 AP V g gjj,g ,y INSPE TED BY: We/s INSH SUPF/ ISSUE COORD. O h' c-/O g

e ~ VA LVE RE INSFECTION CHECKLIST ISSUE H.6.2 s TAG NO. ITEM NO. GE'4. SAMPLE 7

1. G//-04//

32P sue. :A*.tPLE D RIR NO. 6 [r34 VALVE MARKiriGS: YES NO BODY 6 BONtJET ACCE SS. ] { BODY NO. EONNET-f40. T; A li. A flLFY : ACCE' : REJECT [4TE. L._ REtA Ar.k5 : /Sodf OF lMV/s ESulAMC O'MSM S nowy m aw9 [- N'M <WfkJ' gff).nb' l 9 l/f ? b,~ d/ INSPECTEC BY' / / , -38 b ((,. - T'_ ',$ INSR SUP(, " ISSUE COORD., 1 ~

V A LVE RE lhSPECTION CHECKLIST ISSUE BI.6.2 TAG NO. ITEM f40. GEN. SAMPLE 7 2 dd ~ 8#$ 0 27M SUE. LA'IPLE [ RIR NO. PdS(:, VALVE MARKiliGS: YES NO BODY 6 BONtJET ACCE SS. { ] BODY NO. Y o:7/ -/3 9/ EONNET-NO. E MR/o -9 T O A.' 4 O I L : Y.' AC:E'-9 R E JE :.',T ]

4TE:

8/f/RS~ S/V 76-255HV 0" COM MM M"- l nErsA,ss : l l l I I,p t l APP V (25: [, h/ @g,. ,,f,/g,- IN [SPEQTEC BY:S<5?/$ ms~ M9s' INSR SUPF/ 7 ISSUE COORD. c v., s _ n e rux_n

r V A LVE RE INSPECTION CHECKLIST ISSUE BI.6.2 TAG NO. ITEM tJO. GE'4. SAMPLE O /-70/4D 542 sus. EAMPLE [ RlR NO. /3yd* VALVE MARKlf4GS: YE S NO BODY $ BONNET /,CCE SS. [ ] BODY NO. E 34 Q 4 EONNET N'). fd4 7 o -/ O T; A li. A FILt Y.* A C C E '-[ RE,'E',T' "4TE-C 3 f d i REuhnss: LLwe.ogg Pum ax flu 75-/527 -e-n 's Mkvkn - t I e APP y 5: INSPECT (C BY: / / ,g g ~ f /ALA,m.,,. E66r iNse suPo. issue cOORD.

- -. em VA LVE RE lis5FECTION CHECKLIST ISSUE EI.6.2 TAG NO. ITEM NO. GEN. SAMPLE O 2PoV-4//T &7 SUE. LA* IPLE V RIR NO. 2 VT3 VALVE MARKil1GS: YES NO BODY $ BONfJET ACC.E 55. {] BODY NO. S 3 M ~ idO GONNET-NO. W9/ - 9 7 TL A 'i. A 3lL: Y.* FNF AC:i'-{ F.EJET,'j] .LTE- $' 75-/597-5 -/ m' Cwa MTA 34 l Revanks: / (D i AP INSPE CT.E C.BY * ,2 Qfjpj/s/g [ I //4 w f//v,c,Y iNSR SUPV., IS S U E C O'O R D.

VA LVE RE-INSFECTION CHEOKLIST ISSUE E.b.2 i TAG NO. ITEN t10. GE's.SAfdFLE V l ~ /FW-O//4/ /259 SUE.EA:lPLE O RIR NO. /0//0 VALVE MA'iku.G5: YES NO ECDY 6 EONilE 200E 55., ] ECC: NC. D2A -57 t3MB761/ EC+lHE~~ t oo. CVA &7 ?/0 f I 7 A. i ~ f l L. Y.* l A C :E -[ P.EE T[j EATE: $3 REv.snas: 0 de* o>7n ;9x;,w.spig geen yeiE. i l /</ i /.i *Q g 19 - -/9 APPPOVALS: INS E'TEC BY: I '[8wr YMf$ I N C P.

Supp, ISStF COOFD.

CI-O t e - c i RF v. 6 6 +

V A LvE hE INSFEC110N CHECKLIST ISSUE HI.b.2 TAG NC. ITEM NO. GEN SAMPLE T 2-P//d 85 7 SUE. 3A -IPLE V RIR NO. //#df VALVE MARKit.G5: YES NO EODY s EONf!ET 4CCE55. ] EODY NO. - 784 ~ ECNt IE tio. 3857 i ~; A.' E t :l L. Y ' l' l Ac::-[ REJECTU

cTE: MFf/N5 '

i lg) 78 f ogj G yyf (>77;f / M 7E RE:<\\A;kS. I l7bll;' ' /cr 5)N ff g', bl' APPPOVA L5 : 3/['( I N S P. SUPP. ISSUF COOPD. e p A: Ci-Ol e - O f RE V. O

VA LVE RE INSPECT!ON CHECKLIST ISSUE ELb.2 T/ G NO. ITEl4 f10. GEN. SAMPLE 7 gCJ-ggg4 /05 3 SUE. SN.lPLE D RIR NO. 7366~ VALVE MARKINGS: YES NO DODYCBONNET ACCESS. ] /),/f f[7'" DODY NO. N39 5/Il / b2!"hy "'"# YA4 </c bb/ /$ abrna W24 EONilETT NO. //V$$ / TRA CL AelLITY : ACCEPT @ REJECT] DATE: O 9 4 f. f _. REtAhrk5: f 985$O cw CoJE D9M M7f r Co m m is a x (upy-i ) asa /M A2cuf GM A/ww Ave sseasx i/swes. Ao sessie s/h a ss. / fc' e Sod /i Bo<wsr. /18ovs t3.ohw6xr esrisspsopf Bb Wrres

v. d-

? 1.,L/.. a .,a 7 n. W.<c. sp / e. O%4-AYO er-fr 50f g),,hpa O/ Man,- W$4/a s-APPPOVAL5: g / / y/ngs igdh,f/ ~ INSPCOT P Y: q p 1df M,YSJr INSR SUPR. J 5 5 U E C O O'R O. _,._ 01-Ole - 01 ncv.O

M p* VAL.UATION 4 WESEAWCH M M COMPOWATION QA/QC-RT-688 TO: File 1 FROM: M. Obert l DATE: October 2, 1985

SUBJECT:

Review of Procedures Pertinent to Valve Disassembly The following procedures were reviewed including a review of the historical file of previous revision: Procedure No. Title CP-CPM-6.9 General Piping Procedure CP-CPM-6.3 Preparation, Approval, and Control of Operation Travelers CP-CPM-9.18 Valve Disassembly / Reassembly QI-QAP-11.1-39A Valve Disacsembly/ Reassembly QI-QAP-11.1-26 ASME Pipe Fabrication and Installation Inspections l The results of these reviews are reported in Memorandum QA/QC-RT-149 dated 6/19/85 and in the ISAP VII.b.2 Results Report. I M///4 v M. P. Obert MP0/my = '5ZZr. 6.2-7. 0- S C-//

y r li;visient i 11/25/85 Page 1 of 6 ITEF NUMBER VII.b.2 GENERIC SAFETY CONSEQUENCES ANALYSIS TEM DESCRIPTION SAFETY PRESSURE POTENTIAL POTENTIAL CLASS RATING REASSEMBLY ERROR FAILURE & EFFECTS 1 ITT-Grinnell 3 300 psi

1. Bonnet assembly from C.S.

1. No failure.

All bonnets are Stainless Dicphragm Valve valve. Steel with internals of same materials. Manual 3/4 inch Stainless Steel

2. Bonnet assembly from 150 psi

2. No failure. The bonnet and diaphragm valve.

thicknesses are the same for 150 psi and 300 psi valves.

3. Bonnet assembly from non-ASME

3. Code violation.

valve. 2 ITT-Grinnell 2 150 psi

1. Bonnet assembly from non-ASME

1. Code violation.

Dicphrsgm Valve valve. Manual 3/4 inch Carbon Steel

2. Bonnet assembly from ASME III,

2. Code violation.

Class 3 valve. 3 ITT-Grinnell 2 150

1. Bonnet assembly from C.S.

1. No failure.

All bonnets are Stainless Diaphragm Valve valve. Steel with internals of same materials. Manual I inch Stainless Steel

2. Bonnet assembly from non-ASME

2. Code violation.

valve.

3. Bonnet assembly ASME III,

3. Code violation.

Class 3 valve. Lb

2.. b. 2 - C B - G

s Ravicien: 7 11/25/85 Page 2 of 6 ITEM NUMBER VII b.2 GENERIC SAFETY CONSEQUENCES ANALYSIS FEM DESCRIPTION SAFETY PRESSURE POTENTIAL POTEh" RIAL I CLASS RATING REASSEMBLY ELROR FAILURE & EFFECTS b ITT-Grinnell 3 300

1. Bonnet aseeably from C.S.

1. No failure. All bonnets are Stainless Disphragm valve valve.

Steel with internals of same m'aterials. Manual 2 inch Stainless Steel

2. Bonnet assambly from 150 psi

2. a. Possible galling of Stainless Steel valve.

spindle (300 psi valve spindle is brass).

b. No support cushion. Reduced diaphragm life-increased maintenance.

3. Bonnet assembly ~ rom non-ASME

3. Code violation.

valve. i ITT-Grinnell 2 150

1. Bonnet assembly from C.S.

1. No failure. All bonnets are Stainless Diaphragm Valve valve.

Steel with internals of same materials. Manual 2 inch Stainless Steel

2. Bonnet assembly from non-ASME

2. Code violation.

valve.

3. Bonnet asseably from ASME III,

3. Code violation.

Class 3 valve.

e s R;vicirst 1 11/25/85 Page 3 of 6 ITEM NUMBER VII.b.2 CENERIC SAFETY CONSEQUENCES ANALYSIS TEM DESCRIPTION SAFETY PRESSURE POTENTIAL POTENTIAL CLASS RATING REASSEMBLY ERROR FAILURE & EFFECTS ITT-Grinnell 2 300

1. Bonnet assembly from C.S.

1. No failure. All bonnets are Stainless Disphragm Valve valve.

Steel with internals of same materials. Manual 3 inch & 4 inch Stainless

2. Bonnet assembly from 150 psi

2. a. Possible galling of Stainless Steel Steel

valve, spindle (300 psi valve spindle is brass).

b. No support cushion. Decreased diaphragm life-increased maintenance.

3. Bonnet assembly from non-ASME

3. Code violation.

valve.

4. Bonnet assembly from ASME III,

4. Code violation.

Class 3 valve. A ITT-Grinnell 2 300

1. Bonnet and actuator assembly

1. a. Code violation.

Diaphragm Valve from Class 3 valve. Air Operated (ATO)

b. No failure. Actuator action and size 3/4 inch Carbon the came.

Steel B. Stainless Steel 3 300

1. Bonnet and actuator assembly

1. No failure. All bonnets are Stainless from C. Stl., Class 2 valve.

Steel with internals of the same materials. Actuator action and size the same.

R;vicient i 11/25/85 Page 4 of 6 ITEM NUMBER VII.b.2 GENERIC SAFETY CONSEQUENCES ANALYSIS TEM DESCRIPTION SAFETY PRESSURE POTENTIAL POTENTIAL CLASS RATING REASSEMBLY ERROP. FAILURE & EFFECTS A ITT-Crinnell 2 300

1. Bonnet and actuator assembly

1. a. Code violation.

Diephragm Valve from C. Stl., Class 3 valve. Air Operated (ATO)

b. No failure.

All bcnnets are Stainlesa 1 inch Stainless Steel with internals of the same Steel materials. Actuator action and size tae same.

2. Bonnet and actuator assembly

2. Code violation, from non-ASME, 150 psi valve.

B 3 300

1. Bonnet and actuator assembly

1. Same as 2 above.

from non-ASME, 150 psi valve. ( ITT-Grinnell 2 300

1. Bonnet and actuator assembly

1. a. Code violation.

Disphragm Valve from Class 3 valve with ATC Air Operated (ATO) actuator.

b. Incorrect actuator action which would 2 inch & 3 inch be discovered during testing.

Stninless Steel

2. Bonnet and actuator assembly

2. Code violation.

from non-ASME, 150 psi valve. 5 Air Operated (ATC) 3 300

1. Bonnet and ATO actuator

1. Same as 2 above.

assembly from non-ASME, 150 psi valve.

2. Incorrect actuator action which would be discovered during testing.

R;vicinn: 1 11/25/85 Page 5 of 6 ITEM NUMBER VII.b.2 GENERIC SAFETY CONSEQUENCES ANALYSIS lEM DESCRIPTION SAFETY PRESSURE POTENTIAL POTENTIAL CLASS RATING REASSEMBLY ERROR FAILURE & EFFECTS l )A ITT-Grinnell 7 150

1. Bonnet and actuator assembly

1. a. Code violation.

Dicphragm Valve from Class 3, ATO valve. Air Operated (ATO)

b. Smaller actuator. Incorrect actuator 4 inch Stainless action which would be discovered Stcal during testing.

2. Bonnet and actuator assembly

2. a. Code violation.

from Class 3, ATC valve.

b. Incorrect actuator action which would be discovered during testing.

)B Air Operated (ATC) 3 300

1. Bonnet and actuator assembly

1. a. Incorrect actuator action which would from Class 2, 150 psi, ATO be discovered during testing, valve.

l Borg-Warner 2 150 pai

1. Bonnet asn mbly from C.S.

1. a. Corrosion and potential failure of Swing Check valve.

bonnet. Contamination of system from Valve 3 inch & corrosion products. 4 inch Stainless Steel Rev. I

b. Corrosion of C.S. seat.

Loss of leak tightness and check valve function.

R;vici:n: 1 11/25/85 Page 6 of 6 ITEM NUMBER VII.b.2 GENERIC SAFETY CONSEQUENCES ANALYSIS .EM DESCRIPTION SAFETY PRESSURE POTENTIAL POTENTIAL CLASS RATING REASSEMBLY ERROR FAILURE & EFFECTS B:rg-Warner 2 300 psi

1. Bonnet assembly from 150 psi

1. Failure of bonnet seal and/or bonnet Swing Check valve.

cover. External leakage. Valve 10 inch Stsinless Steel

2. Bonnet assembly from C.S.

2. a. Corrosion of bonnet. Potential-failuce valve.

of bonnet. Contamination of system from corrosion products,

b. Corrosion of C.S. seat.

Loss of leak tightness and check valve function.

c. Corrosion and failure of C.S. disk.

I Borg-Warner 2 150 psi

1. Bonnet assembly from C.S.

1. a. Corrosion and potential failure of Swing Check valve.

bonnet. Contamination of mystem from Valve 10 inch corrosion products. Stainless Steel

b. Corrosion of C.S. seat. Loss of leak tightness and check valve function.

c. Corrosion and failure of C.S. disk.

v. 1 05/23/85

/. 5. ERCI systems Integration and Management _ Corporation QA/QC-RT-1638 March 13, 1986 Mr. Frank Milliken ITT-Grinnell Valve Co., Inc. P. O. Box 6164 Lancaster, PA. 17603-2064

Dear Frank:

Enclosed please find a Record of Telephone Conversation for our telecon of March 13, 1986. Please review it for correctness and completeness. Please advise me of any comments at (817) 897-8962. If you have no comments, please note your concurrence (inital and date) and return a copy in the enclosed addressed envelope. s /s & 'l'fi1Ee Obert _" ERC c/o Texas Utilities Generating Co. Comanche Peak Steam Electric Station P. O. Box 1002 Glen Rose, Texas 76043 K 4. 2 gg ["/3 2600 Virgna Avenue NW. Suite 707 Wastnngton. OC 20037 202/342-6795

~ /..\\ ~ l RECORD OF TELEPHONE CONVERSATION / PAGE 1 - OF 1 INCOMING OUTGOING X TIME 10:30 A.M. VM. DATE. March 13, 1986 W d b

Title:

Person called: Frank Millike 0A Division Manaper Representing: ITT-Grinnel Tel. ( 7i ) 241-1901 Person Calling: Mike Obere @,

Title:

ISAP VII.b.2 Issue Coordinator Representing: ERC Tel. ( 8711 897-8962 Other Parties Involved: None TOPICS REF. ITEM 1. I discussed with Mr. Milliken the differences between the bonnet assemblies of an ASME diaphragm valve and a non-ASME diaphragm valve. He stated the differences are as follows: The castings used for making the bonnets are purchased from the foundry by ITT-G under different specifications. For ASME valves, an ASME material spec. is used and for non-ASME valves an ASTM spec. is used. The same pattern is used for the castings of both ASME and non-ASME bonnets. The only difference in the castings is the paperwork that accompanies them. The chemical and physical properties of the metal required by the ASME material spec. are the same properties specified in the AS'IH material spec. The machining of the bonnets for both ASME and non-ASME bonnets is essentially the same. Again the only differences are in paperwork. There is more QA involvement in the repair of any defects found in ASME bonnets. The post manufacturing Non Destructive Examination program is the same for both ASME and non-ASME bonnets so it is not any more likely that a non-ASME valve bonnet with an undetected defect be shipped than an ASME valve bonnet. 2. It is a correct conclusion that there is no functional difference ,between an ASME and non-ASME bonnet. They are physically the same with a different " pedigree" or paperwork package.

s. GOTRREMENT ACCOUNTABILITY PROJECT 1555 Connecicut Avenue. N.W.. Suite 202 Washington. D.C. 20036 (202)232-8550 April 9, 1986 FREEDOM OF INFORMATION ACT REQUEST Director FREEDOM OF INFORMAT!ON Office of Administration EO Nuclear Regulatory Commission [O [ [ -[ 6 Q 7fL Washington, D.C. 20555 & & +H -96 To Whom It May Concern: Pursuant to the Freedom of Information Act ("FOIA"), 5 USC 552, the Government Accountability Project (GAP) requests copies of any and all agency records and information, including but not limited to notes, letters, memoranda, drafts, minutes, diaries, logs, calendars, tapes, transcripts, summaries, interview '.- reports, procedures, instructions, engineering analyses, drawings, files, graphs, charts, maps, photographs, agreements, handwritten notes, studies, data sheets, notebooks, books, telephone messages, computations, voice recordings, computer runoffs, reports, and any and all other records or reports relevant to and/or generated in connection with-all--informa. tion developed silice October _1, 1985 regarding__the' evaluation of Q _. J dividual ISAP omanche Peak, by all staff ~ includin~g consulTaHts. N 6-v v 9 F' -- This request includes all agency records as defined in 10 .-C.F.R. 9.3a(b) and the NRC Manual, Appendix 0211, Parts 1.A.2 and 2 f, A.3 (approved October 8, 1980) whether they currently exist in the NRC official, " working," investigative or other files, or at any other location, including private residences. If any records as defined in 10 C.F.R. 9.3a(b) and the NRC manual, and covered by this request have been destroyed and/or removed after this request, please provide all surrounding records, including but not limited to a list of all records which have been or are destroyed and/or removed, a description of the action (s) taken relevant to, generated in connection with, and/or issued in order to implement the action (s). GAP requests that fees be waived, because " finding the information can be considered as primarily benefitting the general public," 5 USC section 552 (a) (4) (a). GAP is a non-profit, non-partisan public interest organization concerned with honest and open government. Through public outreach, the Project promotes whistleblowers as agents of government accountability. Through its Environmental Whistleblower Clinic, GAP offers assistance to local public interest and citizens groups seeking to ensure the health and safety of their communities. The Environmental Whistleblower Clinic is currently assisting several n. r,,1 m c V fU gV / \\/

Director, Office of Administration Page Two citizens groups, local governments, and intervenors in Texas concerning the construction of the Comanche Peak nuclear power plant. We are requesting the above information as part of an ongoing monitoring project on the adequacy of Region IV and the NRC's efforts to protect public safety and health at nuclear power plants. For any documents or portions that you deny due to a specific FOIA exemption, please provide an index itemizing and derscribing the documents or portions of documents withheld. The iindex should provide a detailed justification of your grounds for claiming each exemption, explaining why each exemption,is. relevant to the document or portion of the document withheld. This index is required under Vaughn v. Rosen (I), 484 F.2d. section 820 (D.C. Cir. 1973), cert. denied, 415 U.S. section 977 (1974). We look forward to your response to this request within ten working days. Sincerely, 1 s l Billie Pirner~ Garde Director, Environmental Whistleblower Clinic BPG:41909C

l GC /ERNMENT ACCOUNTABluTY PROJECT 1555 Connecncut Awnue, N.W., Suite 202 Washington, D.C. 20036 (202)232-8550 June 16, 1986 FREEDOM OF INFORMAT ACT REQUEST Director b'h(fj/ ~ Office of Administration / [ g,j Y[ U.S. Nuclear Regulatory Comnission Washington, D.C. 20555 Re: FOIA Request To whom it may concern: Pursuant to the Freedom of Information Act (FOIA), 5 U.S.C. 552, as amended, the Government Accountability Project (GAP) requests copies of any and all agency records and information, including but not limited to notes, letters, memoranda, drafts, minutes, diaries, logs, calendars, tapes, transcripts, summaries, interview reports, procedures, instructions, engineering analyses, drawings, files, graphs, charts, maps, photographs, agreements, handwritten notes, studies, data sheets, notebooks, books, telephone messages, computations, voice recordings, computer runoffs, any other data compilations, interim and/or final reports, status reports, and any and all other records relevant to and/or generated in connection with the following: The NRC's review of ISAP's I.a.4, I.b.3, II.b., III.de, and VII.b.2, released by Texas Utilities on April 14, 1986. This request includes'all agency records as defined in 10 C.F.R. 9.3a(b) and the NRC Manual, Appendix 0211, Parts 1.A.2 and A.3 (approved October 8, 1980), whether they currently exist in the NRC official, " working", investigative, or other files, or at any other location, including private residences. If any records as defined in 10 C.F.R. 9.3a(b) and the NRC '4anual, supra, and covered by this request have been destroyed and/or removed, or are destroyed and/or removed after receipt of this request, please provide all surrounding records, including but not limited to a list of all records which have been or are destroyed and/or removed, a description of the action (s) taken relevant to, generated in connection with, and/or issued in order to implement the action (s). GAP requests that fees be waived, because " finding the information can be considered as primarily benefitting the gene-ral public." 5 U.S.C. 552(a) (4) (A). GAP is a non-profit, nonpartisan public interest organization concerned with honest and open government. Through its Citizens Clinic, GAP offers assistance to local public interest and citizens groups seeking to ensure the health and safety of their communities. %f. -.,, r e-vOv s -w ,a

.... e.. a FOIA Request June 16, 1986 Page Two GAP is requesting the above information as part of an ongoing monitoring project on the adequacy of the NRC's efforts to protect public safety and health at nuclear power plants. For any documents or portions of documents that you deny due to a specific FOIA exemption, please provide an index itemizing and describing the documents or portions of documents withheld. The index should provide a detailed justification of your grounds for claiming each exemption, explaining why each exemption is relevant to the document or portion of the document withheld. This index is required under Vaughn v. Rosen III, 484 F. 2d 820 (D.C. Cir. 1973), cert. denied, 415 U.S. 977 (1974). We look forward to your response to this request within ten days. Respectfully, k Billie Pirner Garde Citizens Clinic Director 42113 _ _}}