View source for TXX-4827, Forwards Responses to NRC 860515 Questions Re Results Rept for Isap VII.b.2 on Valve Disassembly.No Cases of Using non-ASME Bonnet on ASME Valve Found.Valve Disassembly Accomplished Under Procedure CP-CPM-6.9 Prior to 830128

{{Adams
| number = ML20155K418
| issue date = 05/23/1986
| title = Forwards Responses to NRC 860515 Questions Re Results Rept for Isap VII.b.2 on Valve Disassembly.No Cases of Using non-ASME Bonnet on ASME Valve Found.Valve Disassembly Accomplished Under Procedure CP-CPM-6.9 Prior to 830128
| author name = Counsil W
| author affiliation = TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
| addressee name = Noonan V
| addressee affiliation = NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM)
| docket = 05000445, 05000446
| license number = 
| contact person = 
| document report number = CPRT-455, TXX-4827, NUDOCS 8605280142
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 3
}}

=Text=
{{#Wiki_filter:CPRT-455                                                                LOG NO. TXX-4827 FILE NO. 10068 4*
TEXAS UTILITIES GENERATING COMPANY 0$KYWAY TOWER 400 NORTH D1JVE frTREET. L.B. 81
* DA11AM. TEXAM 7S201 wguay o g,c,o,uyf;',                        May 23, 1986 Mr. Vincent S. Noonan Director, Comanche Peak Project Division of Licensing U. S. Nuclear Regulatory Commission Washington, D.C. 20555

==SUBJECT:==
RESPONSE TO NRC QUESTIONS TRANSMITTED BY LETTER DATED MAY 15, 1986

==Dear Mr. Noonan:==

Attached       please        find     our      responses         to    your      additional comments regarding the results report for ISAP VII.b.2 on Valve Disassembly.
Should you have further questions, please call either myself or Mr. John Beck.
Very truly yours,
                                                            /          0[A'N$
W. G. Counsil WGC:tj Attachment 8605280142 860523 PDR     ADOCK 05000445 hh a ouvusuou or rexas vrrinses stecruic <nuraur                   b
                                                                                                    }

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--                     ISAP VII.b.2 - Valve Disassembly NRC COMMENTS / RESPONSES ITEM 1 COMMENT:     Procedure     CP-CPM   6.9     (Revision   6)  DCN3 requires that procedures be in place to control     the   valve disassembly        process.
This procedure was dated January 28, 1983.
The    implementing      procedure    (CP-CPM 9.18 Revision 0) was issued on June            8,  1983, four    months    later.      Since   valves were disassembled during this period, explain how such activities were controlled.
           ' RESPONSE:    Prior to January 28, 1983, valve disassembly        was      accomplished      under CP-CPM-6.9 including Appendix E (CPM-6.9E).
(Note, a ' CPM is a construction procedure used by craft to perform their work.)            Up to    this    date    CPM-6.9     and   6.9E   (all' revisions)' contained instructions governing valve     disassembly      and    required    valve disassembly to be controlled and documented using operation travelers which contain.the instructions to the craft for the disassembly process.        The issuance of DCN3 to CPM-6.9E (Revision 6) on January 28, 1983, deleted the instructions for valve disassembly, delated the reference to the operations traveler CPM and referenced CPM-9.18. CPM-9.18 was rat issued for use until ' June 8,     1983.      The delay in the issuance of CPM-9.18 was due to the time delay in preparing -the generic valve type checklists      included     as   attachments    to CPM-9.18.      The text section of CPM-9.18 though     not    issued     was   available    and understood by craft on January 28,            1983.
During the four month period in question, valve disassembly continued to be accomplished using operation travelers.           A review of a sample of the travelers written between January 28, 1983, and June 8, 1983, showed them to be similar in content and format to those used prior to the issuance of   DCN3.      Thus,    the valve disassembly process continued unchanged despite the procedural discrepancy.          The issuance of CP-CPM-9.18 (Revision 0) on June          8,  1983, covered all requirements which had been in CPM-6.9E prior to DCN3, including methods of documentation.

NRC COMMENTS / RESPONSES (Cont'd)
ITEM 1 (Cont'd)
Additionally, the pertinent portion of the applicable     quality   assurance     procedure (QI-QAP-11.1.26     Revisions   9   through   !2) including the requirement for a traveler to govern    the     valve   disassembly     process remained unchanged during the four month period.      The use of a traveler and the QI-QAP provided adequate process control during this time frame.
ITEM 2 COMMENT:     Regarding our question number 2 on ISAP VII.b.2 concerning valve bonnets, the use of bonnets without required supporting QA documentation is an apparent violation of          -
the ASME Code.      If the valves at issue are ASME    Code    valves,    in   response    to   a licensing     commitment,     then    appropriate actions must be taken to establish ASME Code     conformance      or,      alternatively, modified licensing commitments must             be submitted to the staff with supporting justification.
RESPONSE:    As stated in the Results Report, there were no cases found of using a non-ASME bonnet on an ASME valve.       The discussion on this subject in the Results Report is provided only as a postulated hypothetical case.}}