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The following information was received from Flowserve US Inc. via facsimile: Description: Contrary to the requirements of ASME Section Ill - NC-4000, Flowserve Raleigh identified that they were utilizing as standard practice, the base material acceptance criteria in lieu of welding acceptance criteria for valves with temporary attachments (i.e. - Lug removal areas). This utilization of criteria has been ongoing as far back as Flowserve's Review could determine. No specific orders or customers are identified as this is systemic to the overall process of valve manufacturing at Flowserve Raleigh. Evaluation: A review was completed of the ASME Code requirements by Flowserve Raleigh's Engineering and Metallurgical Process Control Departments with the following results: The examination of Temporary Attachment Removal Areas, to the NB/NC-2540 Examination and Repair of Forgings and Bars, and NB/NC-2570 Examination and Repair of Statically and Centrifugally Cast Products is contrary to NB/NC-5340 and 5350 acceptance criteria. However, it can be determined that Temporary Attachment Removal Areas examined to NB/NC-2500 acceptance criteria is consistent with the acceptable surface condition resulting from a welded repair performed on the same material product form. No greater risk to pressure integrity is created by the examination of Temporary Attachment Removal Areas to NB/NC-2500 acceptance criteria. The examination of Temporary Attachment Removal Areas examined to NB/NC-2500 acceptance criteria does not result in a Risk to safety relating to pressure integrity. Paragraph NB/NC-4435 of Article NB/NC-4000 FABRICATION AND INSTALLATION contains mandatory requirements for the examination of Components. Contrary to the requirement of NB/NC-4435 (b) (3) to examine the Nonstructural Temporary Attachment Removal Area in accordance with the Acceptance Criteria of NB/NC-5340 or NB/NC-5350 Flowserve performed these examinations in accordance with Article NB/NC-2000 in accordance with the Acceptance Standards of NB/NC-2500 for the applicable Material Product Form. NB/NC-2540 Examination and Repair of Forgings and Bars, NB/NC-2570 Examination and Repair of Statically and Centrifugally Cast Products. ND-4435 contains no mandatory requirements for the examination of Nonstructural Temporary Attachment Removal Area. Extent of Condition: This utilization of criteria has been ongoing as far back as Flowserve's Review could determine. No specific orders or customers are identified as this is systemic to the overall process of valve manufacturing at Flowserve Raleigh. Corrective Actions: Flowserve Raleigh Corrective Action, (CAR-393758) has been issued, and is currently in process of determining root cause and preventive action measures. Summation: After review by Flowserve Raleigh's Engineering and Metallurgical Process Control Departments. It is the position of Flowserve Raleigh, that in accordance with the provisions of 10 CFR Part 21, this condition, while reportable to the NRC (Nuclear Regulatory Commission), is not a significant/substantial safety hazard. Megan Strong Quality Manager office: 919-831-3220 mstrong@flowserve.com

• * * UPDATE ON 10/22/19 AT 1404 EDT FROM FLOWSERVE TO OSSY FONT * * *

In addition to the information previously provided, Flowserve provided the following via fax: Scope/ Extent of Condition: This utilization of criteria has been ongoing as far back as Flowserve's Review could determine. After further review, the scope of impact was determined as cast steel valves, Class 1 and Class 2 only. Anything outside of this criterion would not have been impacted. Corrective Actions: Flowserve Raleigh issued Corrective Action, (CAR-393758), and is continuing their process of completing the root cause and corrective actions needed to prevent recurrence. Actions that have already taken place and/or are in progress are:

  1. ASME Code Training is to be developed, with application toward the criteria as outlined in this Part 21. This training is to be developed to enhance the code knowledge of Flowserve Raleigh Personnel generating Quality Assurance Plans.
  2. Quality Assurance Personnel are to be trained in accordance with the applicable code requirements, to ensure adequate knowledge of the above condition.
  3. Non-Destructive Examination Personnel are to be trained in accordance with the applicable code requirements, to ensure adequate knowledge of the above condition.
  4. Flowserve's Quality Assurance Plans are to have their applicable NOE matrix's revised to incorporate the applicable criteria needed for the removal of temporary attachments.

Summation: After review by Flowserve Raleigh, the following is to be a summation of the above listed 10 CFR Part 21.

  1. The review has determined a programmatic condition that had been existent for many years. Raleigh can only assure that any customers for whom were supplied Class 1 or Class 2 cast steel valves, prior to the issuance of this Part 21 may have this condition.
  2. To date, there have not been any reported failures or technical issues as a result of this condition.
  3. While the above condition is a reportable condition to the NRC, with regards to the violation of the ASME B&PVC Code, it is Flowserve Raleigh's position that it does not pose a compromised condition to safety.

Notified R1DO (Bickett), R2DO (Lopez), R3DO (Stoedter), R4DO (Young) and the Part 21 group via email.