ML20215B725
| ML20215B725 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 01/24/1986 |
| From: | Beck J TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| Shared Package | |
| ML20197E251 | List:
|
| References | |
| FOIA-86-272, FOIA-86-454 ISAP-VII.B.2, PROC-860124-03, NUDOCS 8610080427 | |
| Download: ML20215B725 (8) | |
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COMANCHE PEAK RESPONSE TEAM ACTION PLAN ISAP VII.b.2 TitJe: Vahe risasterbly Eevisier No. 0 1 _,,
Reflects Coments Description Original Issue On Plan Prepared and Recourended by: [
Feview Team Leader rat. ##(,
2y 16 ,,
s e Approved by: . .-
Senior Review Team M_ M. /M k J /2 s f
Date Vf31ff[
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l 8610090427 861003 PDR FOIA GARDE 86-272 PDR Fa m
Rsvision: 1
'. Page 1 of 7 ISAP VII.b.2 Valve Disassembly
1.0 DESCRIPTION
OF ISSUE IDENTIFIED BY NRC (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
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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."
2.0 ACTION IDENTIFIED BY NRC Evaluate the TRT findings and consider the implications of these findings on construction quality. "... examination of the potential safety implications 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.
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.
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R3 vision:
1 1 Paga 2 of 7 ISAP VII.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 t'ype 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 will 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.
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a Rsvision: 1 1 Paga 3 of 7 ISAP VII.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 materials 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 a particular time 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 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 will be made to determine the safety censequences of improperly assembled valves. The analysis will include 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 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 i I
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 l were reassembled using the correct components. A l sample of valves from 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 l
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Ravision 1
.i Pegs 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 considered 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 l 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 I
process of disassembling and reassembling valves.
4.1.5 Manufacturers drawings and disassembly procedures will
! be reviewed and documentation packages will be j 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 i 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.
l 4.2 Procedures I
- Operations, construction and/or QC procedures now in effect will be reviewed and if found satisf actory, will be used for j disassembly, inspectien, reassembly and test as required.
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, 4.3 Participants Roles and Responsibilities 1
The organizations and personnel that will participate in this
, effort are described below with their respective scopes of work.
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R3 vision: 1
> Peg 2 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 Mr. C. Moehlman TUCCO Coordinator 4.3.2 Brown & Root M111 wright Shop 4.3.2.1 Scope Disassemble and reassemble valves, as required, for inspection.
4.3.2.2 Personnel Mr. C. Moehlman TUGC0 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 will be the responsibility of the QA/QC Review Team.
4.3.3.2 Personnel Mr. M. Obert Issue Coordinator
~Mr. C. Spinks Inspection Supervisor
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Ravision: 1 Page 6 of 7
, ISAP VII.b.2 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)
Mr. J. Adam Safety Significance Evaluation Supervisor i ~ Mr. J. L.-Hansel QA/QC Review Team Leader 4.4 Qualifications of Personnel Where inspections require the use of certified inspectors, i qualification.will be to the requirements of ANSI N45.2.6 at j the appropriate level. CPSES personnel will be qualified in j accordance with applicable project requirements. Third-party 1 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, j
- 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 j
The sampling plan will be designed in accordance with the 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 evalurted. 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 s (i.e., two or more), or 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 Permanent.
Equipment Transfers documenting replacement of valve
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Rsvision: 1 8 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 are found, trend analysis will be done and for any adverse trend identified a root cause and generic implication analysis vill be performed. Any QA/QC Program deficiencies found will'.be identified to the QA/QC Programmatic Issue Supervisor for analysis.
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