ML20205F616

Response to ASLB 860414 Proposed Memorandum & Order Re Encl Action Plan Results Rept VII.b.2.Plan Developed in Response to Allegations of Improper Interchange of Valve Parts. W/Certificate of Svc.Related Correspondence

ML20205F616
Person / Time
Site:	Comanche Peak
Issue date:	08/14/1986
From:	Hansel J TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
References
CON-#386-357 OL, NUDOCS 8608190269
Download: ML20205F616 (43)

Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD

)

In the Matter of )

) Docket Nos. 50-445-OL TEXAS UTILITIES ELECTRIC ) SG-446-OL COMPANY et al. )

) (Application for an (Comanche Peak Steam Electric ) Operating License)

Station, Units 1 and 2) )

)

ANSWERS TO BOARD'S 14 QUESTIONS (Memo; Proposed Memo of April 14, 1986)

Regarding Action Plan Results Report VII.b.2 In accordance with the Board's Memorandum; Proposed Memorandum and Order of April 14, 1986, the Applicants submit the answers of the Comanche Peak Response Team ("CPRT") to the 14 questions posed by the Brard, with respect to the Results Report publishad by the CPRT in respect of CPRT Action Plan VII,b.2.

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First Request:

Produce copies of any CPRT-generated checklists that were used during the conduct of the action plan.

Response

The checklist used can be found as Attachment 6.2 to QI-018, Revision 0, dated 7/29/85. The instruction along with Change Notice 001, dated 9/19/85, and Change Notice 002, dated 3/21/86, are attached.

Question:

1. Describe the problem areas addressed in the report. Prior to undertaking to address those areas through sampling, what did Applicants do to define the problem areas further? How did it believe the problems arose? What did it discover about the QA/QC documentation for those areas?

How extensive did it believe the problems were?

Answer:

This Action Plan was prepared to respond to a specific technical concern raised by the NRC Staff's TRT. In the course of investigating allegations to the effect that site personnel had improperly interchanged parts of diaphragm type valves during installation, the TRT investigated the state of installed diaphragm valves and the processes involved in their installation. The TRT inspected thirty-two valves and found three valves with mismatched parts, although the r

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interchanged parts had the same temperature and pressure ratings. The TRT then posed the requirement to TUGCO to, investigate the matter further.

As written in SSER No. 11, the TRT concerns seemed'to be dual in nature. One concern was about potential interchange of valve parts that arose due to

. a lack of control during disascembly and reassembly, and additionally, a perceived lack of corrective action on TUG 00's part. The second concern was about the actual hardware installed in the plant, i.e., did the lack of control result in inadequate valve parts being

'N installed? This report deals with only the lack of control as it affects hardware installation and the hardware itself. The Results Report for ISAP VII.a.2 will deal with the lack of corrective action.

We determined early on that it was physically possible for parts from differently rated valves to be interchanged without being obviously wrong. This, coupled with the large number of valves being disassembled at any one time, led us to agree with the TRT assessment that there was a potential for installation of valves with incorrect parts. This led to the conclusion that reinspection of valves was

e necessary. Although preliminary investigations indicated that the problem was confined to the TRT-identified valve type (diaphragm valves), it was decided to include all disassembled valves in the population to be conservative. One sample was taken from the large population, and one was taken from the smaller subset of valves identified by the TRT.

The results of the reinspection indicated that only the sraaller population of diaphragm valves (regardless of system) have undocumented parts interchanged. The safety implications of this parts interchange are nil in that analysis shows that for this particular valve type, there is no substantive effect on the functionability of the. valve. .

The earlier QA/QC documentation (Operation Traveler) did not contain enough detailed information to preclude interchange of parts. From late 1980 to 1983, the documentation underwent an evolutionary change that became final with the issue of new procedures in 1983.

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O Question:

2. Provide any procedures or other internal documents that are necessary to understand how the checklists should be interpreted or applied.

Answer:

The procedure used with the checklist and the checklist itself are straightforward requiring little or no interpretation. They are provided in response to the opening request.

Question:

3. [ Original acceptance checklists. See Transcript of the Pre-Hearing Conference of April 22, 1986, at 24,353-57.]

Answer:

Attached is the portion of QI-QAP-11.1-26, Revision 18, which pertains to valve disassembly / reassembly and the QC checklist for Valve Disassembly / Reassembly Inspection (QCV checklist).

Prior to use of this checklist, valve inspections were performed using the operation travelers themselves. A point-by-point comparison of the CPRT checklist with these travelers is not meaningful; the shortcoming of the travelers caused the problem. The CPRT checklist was designed to check only specific attributes which the traveler lacked, i.e., body and bonnet serial numbers.

Question:

4. Explain the extent to which the checklists contain fewer attributes than are required for conformance to codes to which Applicants are committed to conform.

Answer:

The checklist used for the ISAP contains all attributes pertinent to the portion of the code applicable to the identification of interchanged valve parts. In particular, it requires checking that the external markings on the body and bonnet of the valve are traceable to the code required Manufacturer's Data Report (NPV-1).

Question:

5. (Answer question 5 only if the answer to question 4 is that the checklists do contain fewer attributes.) Explain the engineering basis, if any, for believing that the safety margin for components (and the plant) has not been degraded by using checklists that contain fewer attributes than are required for conformance to codes.

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a Answer:

The engineering basis for the check list employed by CPRt containing fewer attributes has already been discussed in the response to questions #3 and #4 above.

Question:

6. Set forth any changes in checklists while they were in use, including the dates of the changes.

Answer:

The checklist was not changed after the original issue. The two change notices to the procedure (QI-018) did not change the checklist. Change Notice 001 clarified how the checklist was to be employed for one specific valve type. Change Notice 002 was strictly administrative with no effect on the checklist.

Question:

7. Set forth the duration of training in the use of checklists and a summary of the content of that training, including field training or other l

practical training. If the training has changed or retraining occurred, explain the reason for the changes or retraining and set forth changes in duration or content.

Answer:

l l The two inspectors involved in this ISAP reviewed QI-018 and had all questions on the procedure and checklist answered by the Issue coordinator in a review t

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session of approximately 45 minutes in length. This was documented through use of Record of Assigned Reading sheets in the certification files of the inspectors.

The inspection process was straightforward and involved little judgment on the part of the inspectors.

This training was repeated for Change Notice 001 to QI-018 which clarified inspection requirements for certain valves (see response to Question 11). (Change Notice 002 did not affect the reinspection process).

Question:

8. Provide any information in Applicants' possession concerning the accuracy of use of the checklists (or the inter-observer reliability in using the checklists). Were there any time periods in which checklists were used with questionable training or QA/QC supervision? If applicable, are problems of inter-observer reliability addressed statistically?

Answer:

There is no reason to suspect the accuracy of any inspections performed for this ISAP. There were no r periods of questionable training or QA/QC Supervision.

l There is no statistical basis for determining inter-l observer reliability for this ISAP.

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e Again, the reinspection process was straightforward, with little potential for error.

Question:

9. Summarize all audits or supervisory reviews (including reviews by employees or consultants) of training or of use of the checklists. Provide the factual basis for believing-that the audit and review activity was adequate and that each concern of the audit and review teams has been resolved in a way that is consistent with the validity of conclusions.

Answer:

An NRC Inspection conducted between August 1-31, 1985, included an evaluation of ERC Inspector Certification. As part of this evaluation a review was made of the certification files of both inspectors involved with this ISAP. No deviations were found that pertained to inspectors involved in this Action Plan.

An NRC Inspection conducted between August 23 -

September 30, 1985, reviewed the CPRT program for personnel objectivity and inspector testing. No deviations were found pertaining to inspectors involved l

in this ISAP.

l An ERC Corporate Audit Team conducted an audit

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between September 23 - 26, 1985, which included a review of the certification files for one of the two i

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inspectors who participated in this ISAP. No deviations were found. This audit team was comprised

. entirely of personnel certified as Lead Auditors in accordance with ANSI N45.2.23.

It should be noted that approximately 95% of the inspections for this ISAP were conducted during the periods of time covered by the above-mentioned audits.

Eight (8) reinspections out of a total of 106 reinspections were witnessed by an NRC-inspector.

Independent NRC inspections were performed on five additional valves. The results of the inspections indicated that no deviat3nns existed.

At least 92 completed checklists were reviewed by an NRC inspector for compliance to requirements. The inspection report disclosed no deviations in these checklists.

Question:

10. Report any instances in which draft reports were modified in an important substantive way as the result of management action. Be sure to explain any change that was objected to (including by an employee, supervisor or consultant) in writing or in a meeting in which at least one supervisory or management official or NRC employee was present.

Explain what the earlier drafts said and why they were modified. Explain how dissenting views were resolved.

Answer:

There were no objections to any of the changes suggested by the Senior Review Team (SRT). (The Issue Coordinator doesn't know if these people would be considered " management" or not.) All substantive changes were in the form of additions of material on which the first issue of the Results Report was silent.

The first substantive change was the inclusion of an evaluation of the effect of placing a non-ASME bonnet on a ASME class diaphragm valve. There were no cases found where this had occurred, but the SRT and the Review Team Leader agreed that addressing this potential problem on a hypothetical basis was beneficial in closing the issue. This addition was made to Section 5.2, Page 12, and Section 5.3, Page 17.

The only other substantive change was the j addition of the discussion of the NRC's hypothesized root cause to Section 5.4, Page 18. This discussion is required by Attachment 5 to the CPRT Program Plan (Revision 3) but was omitted through oversight in the original draft of the Results Report.

Question,

11. Set forth any unexpected difficulties that were encountered in completing the work'of each task force and that would be helpful to the Board in understanding the process by which conclusions were reached. How were each of these unexpected difficulties resolved?

Answer:

After inspections began for this ISAP it was discovered that the numbers on the NPV-1 Forms of one manufacturer identifying the body and bonnet markings were not unique to an individual valve. The number was stamped on the body and bonnet but could also be stamped on another valve. Other forms provided by that manufacturer listed the unique serial number for the valve components. Change Notice 001 to QI-Ol8 (attached per the opening request) was issuec to ensure the unique serial numbers were used for this valve type.

An internal audit of the sample selection process for this ISAP revealed an error in the selection of replacement sample items for items initially selected

satisfying the criteria of both the general sample and l

TRT issue sample and then found to be inaccessible.

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e Correction of the error required the selection and inspection of four (4) additional sample items.

The internal audit also revealed a mathematical error in the computation-of one random sample selection requiring one additional sample item inspection to ensure no bias was introduced.

Question:

12. Explain any ambiguities or open items left in the results report.

Answer:

Insofar as the Review Team Leader and the Issue Coordinator can determine, no open items or ambiguities exist in the Results Report.

Question:

13. Explain the extent to which there are actual or apparent conflicts of interest, including whether a worker or supervisor was reviewing or evaluating his own work or supervising any aspect of the review or evaluation of his own work or the work of those he previously supervised.

Answer:

There are no conflicts of interest for the CPRT personnel involved in the implementation of this ISAP.

I Question:

14. Examine the report to see that it adequately discloses the thinking and analysis used. If the language is ambiguous or the discussion gives l

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.e rise'to obvious questions,; resolve the ambiguities and anticipate and resolve the questions.

Answer:

This Results Report has been reviewed again by the Review Team Leader and Issue Coordinator and the following clarifications / background is provided.

Item 1. In Section 5.1, page 10, first paragraph, the reciew of travelers'for internal component serial numbers is discussed. During this review, it was noted that for two valves, the internal component serial' numbers differed on different operations travelers for the subject valves. Prior to issuing the packages for these valves the Issue Coordinator verified, through the valve manufacturer, that more than one set of identification numbers is stamped on the internal components, and that the numbers indicated on the travelers were both correct for the valves in question. Therefore, the Issue Coordinator concluded that the differences in the travelers did not indicate improper reassembly, and so 1

noted this in the verification packages.

Item 2. Section 5.2, page 14, first paragraph, discusses the two valves with deviations that were I

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apparentl'y issued for installation already discrepant with their respective NPV-1 Forms. Prior to submission of the Results Report, the Review Team Leader attempted to resolve the question of when and how these deviations happened.

Through discussions with ITT-Grinnell, it was learned that once a valve and its associated documentation is received by the. owner, the official documentation becomes the responsibility of the owner.

ITT-Grinnell periodically discards valve documentation after a period of time and there is no assurance that all the files from the period of time in question are complete, so a search of the manufacturer's files for the origin of the valve bonnets in question would be inconclusive.

The ITT-Grinnell files for the two valves in question were still available in their files and a review ot these data packages by the ITT-Grinnell QA Manager revealed no unusual time gaps between I inspection points or any reason to suspect that the l

l paperwork shipped with the valves was incorrect. This i

included the sign off by the third-party ANI which does include a check of individual body and bonnet numbers i

T' against the paperwork. The conclusion is that the paperwork associated with the valves at the time of shipment was probably correct although there is still a chance of an error in the manufacturer's shop.

The Receipt Inspection at CPSES checked that the documentation was complete for the valve assembly received. No check of individual component numbers (body and bonnet identification numbers) was made. In the opinion of the Review Team Leader, the CPSES receipt inspection is consistent with general practices in the industry.

No plausible reason has been discovered for disassembly of the valves between the time of receipt on site and issue for installation. Although a discrepancy exists in the documentation, there is no doubt that the valves are adequate for the service intended. Therefore even though no answer exists, the

( conclusions of the results report are unaffected.

Item 3. In Section 5.2, page 14, fourth paragraph, the use of procedure CP-CPM-6.9 is i

discussed. Subsequent to submission of the Results Report it was discovered that a portion of this procedure dealing with valve disassembly was deleted l

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and changed to reference a new procedure, CP-CPM-9.18.

This change occurred four months prior to the official issue of the new procedure. However, the valve disassembly / reassembly process continued unaffected during this four month period despite the procedural break.

Item 4. Section 5.2, page 15, first paragraph, contains a discussion of where valve part3 are stored.

It should be noted that valve parts of any size can be stored in the vicinity of the valve if it is to be reassembled within a "short period" of time. Diaphragm valves disassembled for installation always remained disassembled for an " extended period of time," hence they were stored in the millwright shop.

Item 5. In Section 5.2, page 15, third paragraph, a discussion of the millwright storage area is given. Subsequent to submission of the Results Report, a surveillance was performed by the Issue Coordinator of the disassembly of a diaphragm valve by the Start-up Group. This surveillance showed that all current procedural requirements are being followed.

However, it was noted that valve part storage by Start-Up is treated separately from Construction in that ,

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,. 1 Start-Up has their own separate acorage area located at the warehouse versus the m111 wright shop. The systems to control parts used by construction and Start-up are virtually identical and so the concluulon as to the adequacy of current valve storage practices is unaffected.

j Item 6. section 5.3, page 17, second paragraph, discusses code class deviations. " code class deviations # as used in this report means finding a lower class bonnet installed en a valve body of a higher class (1.g. , a class 3 bonnet on a class 2 body).

Respectfully submittsd,

. ash nus L. Bassel '

ality of Construction Review Team Leader

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WUb W 'Ob !!!W/- RUPEb bH/bl/-WGW-bWh! PWLE.04 l i

m Michael Obert Action Plan VII.b.2 Issue Coordinator The foregoing responses have been reviewed and are concurred in by the CFRT Denior Review Team.

P g21 of 4 EVALUATION RESEARCH CORPORATION COMANCHE PEAK RESPONSE TEAM QUALITY INSTRUCTION FOR ISSUE SPECIFIC ACTION PLAN VII.b.2 INSTRUCTION NO: QI-018 REVISION: 0 EFFECTIVE DATE: 7 'N -W ERINFORMATC cay REINSPECTION OF PREVIOUSLY DISASSEMBLED VALVES j Prepared by: / 3 Date: 7/.24 #f i i Approved by: f/ M N Date: 7/24' #> '

Issue Coordinator " /

i Approved by: Date:

l On-Site QA Representative Approved by:

Rdvles Team leader Date: 7!7h!7f' Q / '

mcar. 4.1 g - -

0I-018 Rsv. 0

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1.0 PURPOSE To provide methods and documentation to be used and accept / reject criteria to be applied when performing reinspection of valves.

2.0 APPLICABILITY This instruction applies to reinspection of samples selected from the population of valves which have been disassembled / reassembled at Comanche Peak Units 1, 2 and areas common to both units.

3.0 REFERENCES

3.1 CPP-010, Preparation of Deviation Reports 3.2 CPP-Oll, Population Evaluation and Reports 4.0 GENERAL Reinspections are performed and documented in accordance with this instruction and established project procedures and instructions. This instruction establishes the documentation to be used, the attributes and accept / reject criteria for reinspections of valves.

5.0 INSTRUCTION 5.1 Documentation

! 5.1.1 The specific valves to be reinspected are identified on Attachment 6.1.

5.1.2 The ERC Issue Coordinator or designee will assemble an inspection package consisting of all the documents pertinent to each specific valve. Each package will contain a checklist similar to Attachment 6.2 specific to that particular valve.

The package will also contais a package content sheet listing all drawings, travelers, Permanent Equipment Transfer's (PET's), receipt inspection information, and any other documents in the package. (Refer to Attachment 6.3.)

5.1.3 When the package has been assembled, the Issue Coordinator will l

make an entry in a log similar to Attachment 6.4 and send the package to the Inspection Supervisor.

5.1.4 On receipt of the package, the Inspection Supervisor will ensure that it is logged on an index similar to Attachment 6.5.

He will then issue the package to a qualified inspector.

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QI-018

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5.2 Inspect' ion 1

l .5.2.1 The Inspector shall locate the valve and. verify the valve body and bonnet markings are accessible for visual inspection (e.g.,

free of insulation).

NOTE: If the valve markings are not visible so note on the checklist and return the package to the Inspection Supervisor for logging out. A new sample valve will be selected.

5.2.2 Record markings of the valve body and bonnet on the checklist.

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l 5.2.3 Verify that the markings found are consistent with those found in the receipt inspection report (RIR). The markings will differ according to the manufacturer but in all cases must be traceable to the form NPV-1 in the RIR. Failure to be

traceable is cause for rejection.

NOTE: Valves which have PET's documenting replacement of valve bonnet's and for which the new bonnet is traceable to a form NPV-1 of a valve. of identical make, pressure rating, temperature rating, metalurgical type, I and code class are acceptable.

I 5.2.4 The inspector shall complete the checklist and route the package to the Inspection Supervisor for his review. The Inspection Supervisor will log the package out and send it to the Issue Coordinator for review.

5.2.5 Should the reinspection revual any inconsistency or abnormality l the Inspector shall process a Deviation Report in accordance

! with Reference 3.1.

In addition to the determination of the necessity of a Safety Significance Evaluation the Issue Coordinator will also indicate in block 16 of the deviation report if disassembly of the valve for verification of the valve internals is to be performed. Should the Issue Coordinator determine that proper valve reassembly is suspect he will so indicate this on the DR and will request that TUCCO Mechanical Engineering have the valve disassembled. The Issue Coordinator will write reinspection instructions on a case basis and will coordinate with TUGC0 Mechanical Engineering to ensure necessary hold points are included in the Operational Traveler to allow for the ERC Inspector's presence at the appropriate time.

5.2.6 The overall results of the sample inspection shall be evaluated in accordance with Reference 3.2 3

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QI-QL8

. Rev. 0 6.0 ATTACHMENTS 6.1 Specific valves to the reinspected:

6.la General Population Sample 6.lb Subpopulation Sample 6.2 Checklist 6.3 Inspection Package Content Sheet 6.4 Inspection Package Log 6.5 Inspection Package Index i

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,, , ATTACHMENT G.I 6 .;,

QI- Ol8 REV.0 .

O~ l VALVE NO. SYS ITEN NO. PAGE REMARKS e i

.......... .... ....... e.... ...................se...eeemene. . eeeeeeee.............eeeee............................ J .

1 PCV uI15 CS 90 ITA03 SUB. SAMPLE e 1 70IOB CS 9I ITA05 SUB. SAMPLE e -

2 70 TOE CS 105 ITA07 GEN. & SUB. SAMFtE e d I 7041 CS II6 ITA09 SUB. SAMPLE e 1 7046 CS 117 ITA09 SUB. SAMPLE *' .,

- 2 7041 CS 127 ITA10 SUB. SAMPLE e

• 2 7022 CS 129 ITA10 SUB. SAMPLE e 2 0245 CS 132 ITAIO SUB. SAMPLE e 2 CS 7016B CS 153 ITNot SUB. SAMPLE e d.

2 CS 70160 CS 155 ITNot GEN. & SUB. SAMPLE e 2 CS 7016E CS 156 ITNot GEN. & SUB. SAMPLE e 2 CS 0119 CS 157 ITNot SUB. SAMPLE e d X CS 0038 CS 102 ITN05 SUB.GAMPLE e X BR 8640 BR 197 1TMO6 GEN. & SUB. SAMPLE e I 2' CS B376 CS 201 ITHO7 SUB. SAMPLE e *

• 1 CS 8376 CS 213 ITNO9 SUB. SAMPLE e I N BR 8635B bR 266 ITN13 SUB. SAMPLE e .

2 CS 70400 CS 271 ITNt4 SUB. SAMPLE e w 2 CS 7012D CS 278 ITNI5 600. SAMPLE e f 2 CS 7013A CS 200 ITMI5 SUB. SAMPLE e ,

2 CS 7013E CS 2u4 ITN15 SUB. SAMPLE e b 2 CS 7017D CS 280 ITN15 SUB. SAMPLE e 2 CS 704Bu CS 291 11NI5 SUB. SAMPLE o 2 CS 8396A CS 293 ITNI6 SU9. SAMPLE e w' 2 CS B439 CS 296 ITNI6 SUD. SAMPLE e 2 CS 8432 CS 299 ITN16 SUB. SAMPLE o 2 CS 8444 CS 299 ITMI6 SUB. SAMPLE e w'

• 2 CS 7012A CS 304 ITN16 GEN. & SUS. SAMPLE e X CS 9456 CS 366 ITN22 SUB. SAMPLE e 1 CS 7013A CS 397 ITN25 GEN. & GUB. SAMPLE o d 1 CS 7013B CS 398 ITn25 GEN. & SUB. SANPLE e 1 CS 7017D CS 405 ITM25 GEN. & SUB. SANPLE e ..

M BR 8591 BR 419 ITN27 SUB. SAMPLE e w'

• 2 BR 8553 bR 422 ITN27 GEN. & SUD. SAMPLE e 2 8422 CS 435 ITM29 GEN. & SUB. SANPLE e 2 0425 CS 436 ITN29 GEN. & SUB. SAMPLE o d 2 0390b CS 449 ITN30 SUB.GAMPLE e 2 0400 CS 450 ITN30 SUB. SAMPLE o ,. e 2 0416 CS 451 ITM30 SEN. & SUR. SAMPLE e 'J 2 7011C CS 4"i6 ITM31 SUB.GANPLE

• 2 701SE CS 458 ITN31 '

GEN. & SUB. SAMPLE e 2 7014C CS 461 ITN31 SUB. SAMPLE o U 2 U463 CS 467 ITN36 SUB.GAN11C e 2 7046 CS 471 ITN32 GEN. & Sub. G#J1PLE e . .

2 7002A CS 472 ITM32 SbB.EAMPLE e J

• 2 7007 CS 478 ITN32 DCN. & GUB. SAMPLE e  !

1 0427 CS 564 11N34 SUB. SAMPLE e 1 -8 4 H2 CS 566 ITM34 GEN. & SUB. SANFLE e J 1 0404 CS 50/ ITN34 GEN. & SUB. sat'.F LE e 84614 CS 500 ITN35 GEN. & GUB. SAMPiE e 1 CS G560 CS 513 ITM35 500.SANFtE e J l 7014E CS 523 ITM36 SUR. sat 1FtE a l .

I J ,

t I ....

1

f

..m 2 ATTACHMENT 6.1.6 o Q1-018 ,

REV.O 'l VALVE NO. SYS ITEM NO. PAGE RE m 'S . +

1 7003A CS 529 ITN37 SUB. SAMPLE .

t 0571 M 548 ITN38 SUB. SAMPL E .

t 0577A BR 553 ITH30 SUB. SAMPLE . U' X SF 0162 SF 572 ITN40 SUB.SANPLE a i X SF 0179 SF 573 ITN40 SUB. SAMPLE .

• 1 Sr 0053 SF 575 ITN40 GEN. & SUS. SAMPLE . O I

1 0554b bH 658 ITN50 SUB. SAMPLE .

1 0570 IA 666 NW-09 SUB. SAMPLE .

g 9

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. Attrchment 6.2 QI-018 Rev. 0 l -_ .

VALVE Rf triSLECTIGN CHCCKUST ISSUE III.1..2 TAG NO. ~  ; TEM fJQ. C-EN. S e pt,g Q 1

s n.s wput D R.IR NO.

VALVE MAkKING5' YES No E:007 C 80Nf1CT ACOE55. 9 CCCrv NO.

EON"ET f;T b TRA 0EAEiUTY :

R g. ATE t ACCEPT]

REMARKS:

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I APPPOVALS: r IN$FE;iEC Sy:

INSR SUFR. 159ur ; C 0 c 3.

Cl- Ol e - 01 RE v. 0

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I 1

I

. . Actrehment 6.3 QI-018 Rev. 0 e

I E

l l VALVE DISASSDSLT = TSSUE V11.t.2 INSFECTION PACKAGE CCkTDIT EBEET ISSUE DATE POP. INSPEC. PROCED. SAMfL1 IDENT. PAGE OF f QI418 Gnf. _ k

'" - (A i FALVI TAG ho. ITEM No, 3 52 'Icli . u0.

A _

92 VISION / OF DOCL'MfNT FC. DAtt DOCCHZNT DESCRIPTION PACEI A Jb

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• PAEPAR D SY ,; ATE RLY[EUE3 5Y3 LAIE

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. 1 Attrchment 6.4 QI-018 Rev. 0 VALVE DISASSIMBLT - ISSUE VII.b.2 INstEcT!oN PACKAGE IDG

^

INSrEcT!oN sAnttr PACKACE NO. IDDrf. VAtVE TAG No. ITEM No. NAME/SICNATURF A EDUutK5 Y( A

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A \v/

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Attcchment 6.5 QI-018 Rev. O i

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VALVE DISAS$DSLY - 155cE T!!.b.2 INsrEcTIon rAcxAct INnEx A

ENTRY IN$rECTION DATE DATE TO NO. rACKAGE NO. RECE!VED ENCINEn I

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l Ql-018 -02 REv.0 -

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I . .

, Pcg2 1 of 2 EVALUATION RESEARCH CORPORATION ON 0 b COMANCHE PEA QUALITY INSTRUCTION FOR ISSUE SPECIFIC ACTION PLAN VII b.2 CHANG 2 NOTICE 001 INSTRUCTION NO: QI-Ok8 -

l, REVISION: 0 ,

ISSUE DATE: 09/19/85 l REINSPECTION OF PREVIOUSLY DISASSEMBLED VALVES The QI identified above is hereby changed as shown on the attached pages of this notice.

W ]

Prepared by: " Date: f/A'

/

N Approved by: / Date: 9 f/ J' Issue Coordinator Approved by: . Date: 9-/9- W l

On-Site QA1tepresentative Approved by: ___ r t Date: Y /f YT "

Q Review Team Leader '

me -

Chinga Notica 001

, QI-018 Rev. 0

1. Add following note to paragraph 5.2.3.

NOTE: For Borg-Warner valves the number listed on the NPV-1 is an

'N' code and is not unique to the particular component being inspected. Borg-Warner Form ' ATP' in the RIR lists the 'N' code, piece number, and serial number. The serial number is unique and should be used for the purpose of the inspection.

If a reinspection has been completed using the 'N' code the Inspector should obtain the completed package from Records Administration, and reperform the inspection using the serial number. This inspection is to be documented on the original checklist and the package should be reviewed as per the original inspection. The Issue Coordinator will return the package to Records Administration.

The following packages are to be reinspected in the above_ .

manner: .

Package Numbers 1

~

3 98 99 100 122 136 l

2

f.

.. Pcg3 1 of 2 EVALUATION RESEARCH CORPORATION FGR C?0:lMATIM cmy COMANCHE PEAK RESPONSE TEAM QUALITY INSTRUCTION FOR ISSUE SPECIFIC ACTION PLAN VII.b.2 CHANGE NOTICE 002 INSTRUCTION NO: QI-018 REVISION NO: 0 ISSUE DATE: 03/21/86 REINSPECTI0l' 0F PREVIOUSLY DISASSEMBLED VALVES The QI identified above is hereby changed as shown on the attached pages of this notice.

f- X ) /

Prepared by: [M D Date: 3//t/#4 e

Approved by: [Mw Date: 3 7 4 Issue Coordinator Approved by: . [. fy A Av ative Date: .3 4!f4 On-Site QA Repres A,,r v.d ,: !dLA nat.:

d.ua .

,A,7..vI..,....d.r

%. b.2- 3, b ~3

f *

' ' Cheng3 Notica 002 QI-018 REV. 0

1. Change paragraph 5.1.1 to read as follows:

5.1.1 The initial sample of valves to be reinspected is identified on Attachment 6.1. As new sample items are picked (e.g., to replace inaccessible items) the ERC Issue Coordinator will maintain an updated listing of the specific valves to be reinspected.

9 2 .

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2.-s

/ BROWN & ROOT, INC. B&R INSTRUCTION  ;

QI-QAP-11.1-26 Rev. 18 l

- CPSES - ((({[ "m))))) Page 11 of 72 '

35 1195 NOV 201985 3.5 MECHANICAL ACTIVITIES 3.5.1 General Installation Requirements

)

Mechanical activities such as installation of mechanical joints or installation, assembly, of valves, etc., shall be performed and inspected in accordance with a Construction Operation Traveler. The OT shall be reviewed and approved by QE/QCE.

NOTE: When it becomes necessary to disassemble / reassemble the valves addressed in Attachments to construction procedure CP-CPM-9.18, the QC checklist for this activity (Attachment 4) will be issued to the documen-tation package.

3.5.2 Construction Operation Traveler 3.5.2.1 General The OT serves as a fabrication / installation / inspection checklist of operations necessary to achieve a quality end product. The OT provides for sequential instructions on how to perform a task, identifies required inspection points, and specifies the documentation for these activities. Accordingly the checklist

details will vary depending on the complexity of the work.

NOTE: The sequence specified on the OT shall be followed unless otherwise approved by QE/QCE. This shall be documented by a QE/QCE in the "0PERATION" block with the words " Operations may be worked out of sequence" or similar words. This is not considered a revision.

3.5.2.2 Typical OT Information Typical OT information shall be as follows:

a. Part, serial, or tag number and material description (s) where applicable,

b. The department assigned the task to perform operation (s).

c. Operation description, methods, procedures / instructions by number and revision and other information as required to

! successfully complete the operation in accordance with applicable requirements. Examination or test procedure /

instruction numbers and revisions shall also be recorded on the OT or supplementing repart for extmination or testing activities.

l

~

l

BROWN & ROOT, INC. B&R INSTRUCTION effu & mw QI-QAP-11.1-26 Rev. 18

- CPSES - ( ) Page 12 of 72 o

35 " 85 NOV 201985

d. All dimensions and tolerances necessary to assure compliance with applicable design drawings and specifications. This information may be given by reference, provided persons performing the work have access to the referenced material.

e. Any needed offsite operations or processing shall be cited in the appropriate sequence with all other operations.

f. Necessary instructions for handling, cleaning, storing and preserving items.

g. Required QC/ANI hold points.

3.5.2.3 OT Development The discipline QE shall participate, as necessary, in the OT development to assure all quality requirements of the governing procedures are adequately addressed and in the proper sequence.

The OT shall contain, or may reference if normally available, the drawings, procedures, instructions, manufacturer's manuals /

guidelines, etc., necessary to accomplish the activity.

l 3.5.2.4 OT Review / Approval As directed by the SQAM QE/QCE shall review the OT for complet-eness, compliance with applicable construction and QA procedures and the equipment manufacturer's manual. The QE/QCE shall indicate QC hold points by entering QC (M), (V) or (W) in colu=n headed " Department" opposite the applicable operation.

i Additionally, the QE/QCE may, if considered necessary, add entire l

' operations directed specifically at the QCI. When all necessary hold points have been established, the QE/QCE will sign the

" Reviewed by" block and forward the OT to the ANI for review. OT not requiring ANI review (work not affecting pressure boundaries or component supports and line valve disassembly / assembly) will be marked 'NA' in the "ANI Review" block by the QE/QCE and initialed and dated.

1 3.5.2.5 Revisions All revisions, regardless of their significance, shall receive the same reviews and approvals required for the original traveler.

e ,~ . . . . - . - , , - , - - -.-4., - - . - - . - . - - - - - - --- - , , - - . . - - - - . - -

l

. BROWN & ROOT, INC. B&R INSTRUCTION were imu um QI-QAP-11.1-26 Rev. 18

- CPSES - ((((( "))) Page 13 of 72

   ,               as. m s NOV 201985
                                                                                                        .                                            1 3.5.2.6       QA/QC/ANI Inspection Documentation of satisfactory completion of each hold point shall be by the appropriate QCI signing and dating the column "QA/QC Eng".

As noted on the OT, one or more quality characteristics may be inspected at an established hold point, as prior work affecting a quality characteristic may be inspected at any time in the process providing there is proper accessibility. All inspection reports, including NDE Reports, generated as a result of the OT shall be attached. If an operation is completed unsatisfactorily, the inspector shall enter "UNSAT", sign and date the column titled "QA/QC Eng."

                           "Unsat" conditions shall be reported in accordance with CP-QAP-16.1.

3.5.2.7 Completed OT Upon completion of all work operations, the responsible QCE shall review, sign and date the last operation in the column titled "QA/QC Eng.", verifying all operations are complete. The OT shall be forwarded to the PFG for inclusion in the applicable Iso package. 3.5.3 Valve Installation Valve stem orientation shall normally be shown on the installation isometric. However, in some cases, this may be impractical; therefore, prior to welding or bolting any valve in the system, its stem orientation shall be checked against the G&H composite drawing, by the QCI. In cases where neither the installation isomeccic or the C&H composite drawing reflects valve orientation, the following criteria shall be utilized. l a. Valves larger than 2" should be brought to the attention of the Engineer for resolution.

b. Valves 2" and smaller --

1. In horizontal lines all valves shall be installed in the stem vertical upright position. When this is not possible, the Engineer should be contacted for resolution.

     ,,m      w-     -                     ey          .-     w.       , _ , - - - - , , , ,          *         - . . , , - . - - --s go.-  --. . w.

F *

.                                                                                                     l BROWN & ROOT, INC.                                          B&R INSTRUCTION
                                       <<<<<imu u m                 QI-QAP-11.1-26 Rev. 18
             - CPSES -                (((({ % }}}})                 Page 14 of 72 e            35 -" '5                                            NOV 2 01985

2. In vertical lines construction judgement should be used to avoid interferences with adj acent piping, structures, etc., and will be operable.

NOTE: The stem and operator orientation of all valves, including manually operated valves, may deviate 5* from design location. Where reorientation is required to avoid interference, valve operators may be rotated in accordance with manufacturer's instructions. On motor operated valves, the operator should be oriented such that the limit switch compartment is not below the gear box. The QCI shall also verify, at fit-up, that the valve flow direction as marked on the valve body is in conformity with the flow direction on the installation isometric. Globe valves shall be installed such that the flow goes under the valve seat, unless otherwise noted on the valve body or the installation isometric. In addition, the QCI shall ensure that all foreign material such as dirt, grease, desicants, etc., are removed from the valve prior to welding. Weld end valves except diaphragm, control and check valves shall be opened approximately 50% prior to welding. All diaphragm valves shall have the diaphragm removed prior to welding. Control valves shall be opened to break contact between the valve seat and the stem. Check valves need not be open. When it becomes necessary as determined by the piping superintendent to install pipe spools adj acent to valves which are not available for installation, temporary spools may be installed in place of the missing valves. For all Code stamped valves, Class 1, 2 and 3, the valve manufacturer's serial number shall be recorded in the Material Identification Block of the WDC. NOTE: All branch valves (vents, drains, test connections) flow shall correspond to flow indication as shown on the appropriate drawing. If no flow indication is shown on the drawing, no inspection for flow direction of affected valve is required. 3.5.4 THREADED CONNECTIONS

F l i BROWN & ROOT, INC. B&R INSTRUCTION e-en zmu um QI-QAP-11.1-26 Rev. 18

                  - CPSES -                        (                         )                Page 45 of 72
     ,              as.u ss                                                                      NOV 2 01985 ATTACHMENT 4 THIS ATTACHMENT IS APPLICABLE TO THOSE VALVES SPECIFICALLY ADDRESSED IN THE ATTACHMENTS TO CONSTRUCTION PROCEDURE CP-CPM-9.18. VALVES NOT ADDRESSED IN Tile ATTACHMENTS SHALL BE DISASSEMBLED / REASSEMBLED IN ACCORDANCE WITH A CON-STRUCTION OPERATION TRAVELER (OT).

ANY NONCONFORMING CONDITION RELATED TO THIS ACTIVITY OR HARDWARE SHALL BE DOCUMENTED IN ACCORDANCE WITH CP-QAP-16.1. QC CHECKLIST POR VALVE DISASSDSLY/ REASSDGLY INSPECTION PAGE 1 0F 2

                                                                      ~

CHECKLIST f QCV-OP. No. OPERATION SAT /UNSAT OCI/DATE

1. IRN NO.

VALVE IDESi!TICATION

2. MFC. SR. NO.

3. VALVE TAC NO.

4 VALVE TYPE AND SIZE VALVE DISA55DGLY:

5. DOCLMENT BODY HEAT NO.

6. DOCLMENT BONNET HEAT NO.

7. DOCLMENT DISC HEAT NO.

(if applicable) , 8. MONITOR VALVE DISASSDGLY AS DESCRIB O IT .TE SL'PPLDENT 4 PACKACE. IDENTIIT AND STORE OF PARTS

10. VALVE BODY PROPERLY COVERO (if applicable)

VALVE REASSDOLYr

                       !!.        VERITT REAT NO. PREVIOUSLY VERIFI D                                               -

l IN STEP NO. 5, 6 and 7 ph

12. VERITY CLEANLINESS OF VALVE BODY Ah"D PARTS 3

13. MONITOR TD&ORARY VALVE RIAS$DGLY L' SING OLD CASKETi la. LIST ALL REPLAC D PARTS PART NAME AND/0R PART NO. E.R.8/0.T.f HI.AT/ LOT NO.

l l l

r l o 1 1 l

• BROWN & ' ROOT, INC. ' B&R INSTRUCTION l e<<< r imu um QI-QAP-11.1-26 Rev, 18

             - CPSES -                     ((((' "m}})))                         Page 46 of 72
     ,         as- m s                                                           NOV 2 01985 ATTACHMENT 4 (continued)

PACE 2 0F 2 QC CHECKLIST FOR VALVE DISASSDSLT/ REASSDSLY IhSPECTION (CONT'D) CHECKLIST # QLV-

                     ?P. NO. OPERATION                                          SAT /L3 SAT    QCI/DATE

15. LU3RICATE THRIADS WITH NEOLUBE OR FEL-PRO N-5000

16. MONITOR VALVE REASSDSLY SEQUENCES AS DESCRIBC IN THE SUFFLEMEC

17. DOCLHENT FINAL TORQUE VALVES A) TORQUE OF PLAIN BODY TO BONNET BOLTSr M&TE TOROUE VALLT B) TORQUE OF MAIN BODY STUDS:

(if applicable) M&TE TDROUE VALL*E C) TOR 0CE OF ETE5GLT RING BOLTS: M&TE TOROUE VALUE D) TORQUE OF CIAND CHASER BOLTS: M&TE TORQUE VALUE l E) TORQUE CF YOKE ADAFTER BOLTS: [ l M&TE TORQUE VALUE F) TORQUE CF _ (LIST IF APPLICA3tE) M&TE TORQUE VALUE

18. COMENTS:

19. QC SUPERVISION REVIEli l

I

2 CERTIFICATE OF SERVICE I, Robert K. Gad III, one of the attorneys for the Applicants herein, hereby certify that on August 14, 1986, I made service of the within " Answers to Board's 14 Questions (Memo; Proposed Memo of April 14, 1986) Regarding Action Plan Results Report VII.b.2" by mailing copies thereof, postage prepaid, to: Peter B. Bloch, Esquire Mr. Thomas F. Westerman Chairman Comanche Peak S.E.S. Administrative Judge c/o U.S. Nuclear Regulatory Atomic Safety and Licensing Commission Board P.O. Box 38 U.S. Nuclear Regulutory Glen Rose, Texas 76043 Commission Washington, D.C. 20555 Dr. Walter H. Jordan Mr. William L. Clements Administrative Judge Docketing & Services Branch 881 W. Outer Drive U.S. Nuclear Regulatory Commisu Oak Ridge, Tennessee 37830 Washington, D.C. 20555 i Chairman Chairman Atomic Safety and Licensing Atomic Safety and Licensing Appeal Panel Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 L Washington, D.C. 20555 Stuart A. Treby, Esquire Mrs. Juanita Ellis Office of the Executive President, CASE Legal Director 1426 S. Polk Street l U.S. Nuclear Regulatory Dallas, Texas 75224 Commission Washington, D.C. 20555 i l l l [

                                                                                 ~

f. 4 Renea Hicks, Esquire Ellen Ginsberg, Esquire Assistant Attorney General Atomic Safety and Licensing Environmental Protection Division Board Panel P.O.-Box 12548, Capitol Station U.S. Nuclear Regulatory Commission Austin, Texas 78711 Washington, D.C. 20555 Anthony Roisman, Esquire Mr. Lanny A. Sinkin Executive Director Christic Institute Trial Lawyers for Public Justice 1324 North Capitol Street 2000 P Street, N.W., Suite 611 Washington, D.C. 20002 Washington, D.C. 20036 Dr. Kenneth A. McCollom Mr. Robert D. Martin Administrative Judge Regional Administrator 1107 West Knapp Region IV Stillwater, Oklahoma 74075 U.S. Nuclear Regulatory Commission Suite 1000 611 Ryan Plaza Drive Arlington, Texas 76011 Ms. Billie Pirner Garde Geary S. Mizuno, Esq. Citizens Clinic Director Office of the Executive Government Accountability Project Legal Director 1901 Que Street, N.W. U.S. Nuclear Regulatory Commission Washington, D.C. 20009 Maryland National Bank Bldg. Room 10105 7735 Old Georgetown Road Bethesda, Maryland 20814 Elizabeth B. Johnson-Administrative Judge Oak Ridge National Laboratory P.O. Bex X, Building 3500 Oak Ridge, Tennessee 37830 l Nancy Williams Cygna Energy Services, Inc. l 101 California Street Suite 1000 San Francisco, California 94111 l Robert K. GapIII l _ _ _ _ -}}