Information Notice 1991-25, Commercial-Grade Structural Framing Components Supplied As Nuclear Safety-Related Equipment

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Commercial-Grade Structural Framing Components Supplied As Nuclear Safety-Related Equipment
ML031190655
Person / Time
Site: Beaver Valley, Millstone, Hatch, Monticello, Calvert Cliffs, Dresden, Davis Besse, Peach Bottom, Browns Ferry, Salem, Oconee, Nine Mile Point, Palisades, Palo Verde, Perry, Indian Point, Fermi, Kewaunee, Catawba, Harris, Wolf Creek, Saint Lucie, Point Beach, Oyster Creek, Watts Bar, Hope Creek, Grand Gulf, Cooper, Sequoyah, Byron, Pilgrim, Arkansas Nuclear, Three Mile Island, Braidwood, Susquehanna, Summer, Prairie Island, Columbia, Seabrook, Brunswick, Surry, Limerick, North Anna, Turkey Point, River Bend, Vermont Yankee, Crystal River, Haddam Neck, Ginna, Diablo Canyon, Callaway, Vogtle, Waterford, Duane Arnold, Farley, Robinson, Clinton, South Texas, San Onofre, Cook, Comanche Peak, Yankee Rowe, Maine Yankee, Quad Cities, Humboldt Bay, La Crosse, Big Rock Point, Rancho Seco, Zion, Midland, Bellefonte, Fort Calhoun, FitzPatrick, McGuire, LaSalle, Fort Saint Vrain, Shoreham, Satsop, Trojan, Atlantic Nuclear Power Plant  Entergy icon.png
Issue date: 04/01/1991
Revision: 0
From: Rossi C E
Office of Nuclear Reactor Regulation
To:
References
IN-91-025, NUDOCS 9103270304
Download: ML031190655 (8)


UNITED STATESNUCLEAR REGULATORY COMMISSIONOFFICE OF NUCLEAR REACTOR REGULATIONWASHINGTON, D.C. 20555April 1, 1991NRC INFORMATION NOTICE NO. 91-25: COMMERCIAL-GRADE STRUCTURAL FRAMINGCOMPONENTS SUPPLIED AS NUCLEARSAFETY-RELATED EQUIPMENT

Addressees

All holders of operating licenses or construction permits for nuclear powerreactors.

Purpose

This information notice is intended to alert licensees to problems in thededication of structural framing components supplied to the nuclear industry bythe Unistrut Corporation (UC), Wayne, Michigan. It is expected that recipientswill review this information for applicability to their facilities and consideractions, as appropriate, to avoid similar problems. However, suggestionscontained in this information notice do not constitute NRC requirements;therefore, no specific action or written response is required.

Description of Circumstances

The most common structural framing components supplied to licensees by UC are1-5/8-inch wide, continuously slotted, structural framing channel members;fasteners; and mechanical accessories such as channel nuts, fittings, and pipeclamps. These components are supplied through a network of nationwideAuthorized Service Centers, some of which are owned and operated by UC.The NRC inspected the UC facilities and records and found that UC had failed toimplement measures to control the dedication of commercial-grade structuralframing components. UC supplied Certificates of Conformances (COCs) statingthat these materials met the requirements of Appendix B to Part 50 of Title 10of the Code of Federal Regulations (10 CFR) and were supplied in accordancewith the provisions of 10 CFR Part 21. UC failed to demonstrate that it had:(1) established an adequate basis for accepting material certifications fromits suppliers of fasteners and coil material, (2) verified the chemical andphysical properties of coil material, (3) performed destructive product testingtraceable to each coil of material used to manufacture structural framingchannel, (4) maintained traceability of the material used to manufacturemechanical accessories, or (5) performed adequate product testing on allmechanical accessories.UC manufactures structural framing channel members from coil material procuredto UC's material specifications from various commercial-grade suppliers andmanufacturers. These suppliers provided material certifications that UCg 27O3O4 4 //

IN 91-25April 1, 1991 accepted without assuring that the coil materials could be traced and identi-fied to the certifications. UC did not perform a destructive product test onstructural framing channel that was traceable to each heat or lot of coilmaterial. Furthermore, UC did not perform tests or examinations to ensure theaccuracy of the chemical and physical properties listed in the material certi-fications. UC supplied the commercial-grade structural framing channel tolicensees as safety-related components that comply with the requirements of theAmerican Society for Testing and Materials (ASTM) Standards, Appendix B to10 CFR Part 50, and 10 CFR Part 21 with COCs stating that these requirementswere met, even though UC did not perform an adequate commercial-grade dedicationof the coil material. In some instances, UC also certified that the channelmet the requirements of the American Society of Mechanical Engineers, Boilerand Pressure Vessel Code (ASME Code),Section III, Class 2, Subsection NF-2600but did not demonstrate compliance with the ASME Code requirements.All fasteners supplied by UC were procured as commercial-grade items from asingle supplier (General Fastener Company of Livonia, Michigan), which furnishedmachine screws, nuts, and washers that were 1/2-inch and smaller. UC procuredthese fasteners according to the Society of Automotive Engineers (SAE) Standardsand supplied them to licensees as safety-related fasteners that comply with therequirements of the ASTM Standards, Appendix B to 10 CFR Part 50, and10 CFR Part 21 with COCs stating these requirements were met, even though UC didnot perform any commercial-grade dedication activities.Mechanical-accessories -are -alsormanufactured by UC-from coil material procuredto UC's material specifications from various commercial-grade suppliers andmanufacturers. These suppliers provided material certifications that UCaccepted without assuring that the coil materials could be traced and identifiedto the certifications. Channel nuts and 90-degree angle fittings are theonly mechanical accessories that receive product tests. UC also did notperform tests or examinations to ensure the accuracy of the chemical andphysical properties listed in the material certifications. UC supplied themechanical accessories to licensees as safety-related components that complywith the requirements of ASTM Standards, Appendix B to 10 CFR Part 50, and10 CFR Part 21 with COCs stating these requirements were met, even though UCdid not perform an adequate commercial-grade dedication of the coil material.Licensees have conducted numerous audits of UC and some have placed UC ontheir approved vendor lists to supply safety-related components. The inspectorsexamined sample audit conclusions and found that they varied widely. Somelicensees found that UC was fully capable of supplying safety-related componentsthat comply with the requirements of Appendix B to 10 CFR Part 50 and10 CFR Part 21, and in one instance found that UC could supply safety-relatedcomponents that comply with.the ASME Code requirements. Other licensees foundthat UC could only supply commercial-grade components. In performing many ofthe audits, licensees did'not identify UC's failure to implement adequatemeasures to control the dedication of commercial-grade structural framingcomponents, indicating a significant weakness in the performance of theseaudit IN 91-25April 1, 1991 Discussion:UC manufactures structural framing components used to support nonsafety andsafety-related components such as pipes, instrument lines, ducts, cable trays,and conduits. The NRC has not identified a significant safety concern orin-service failure regarding the known applications of these structural framingcomponents. However, structural framing components were supplied by UC assafety-related and may be installed in safety-related structures, systems, orcomponents and may not meet quality standards commensurate with the importanceof the safety function to be performed. Therefore, licensees may wish toreview their use of structural framing components to confirm that the procuredequipment is acceptable. In addition, licensees may wish to examine theadequacy of applicable audits and their audit process.This information notice requires no specific action or written response. Ifyou have any questions about this matter, please contact one of the technicalcontacts listed below or the appropriate NRR project manager.Directo~rDivision of Operational Events AssessmentOffice of Nu-clear Reactor-RegulationTechnical Contacts: Steven M. Matthews, NRR(301) 492-3191Stewart L. Magruder, NRR(301) 492-3220

Attachment:

List of Recently Issued NRC Information Notices 2-40D 1XC?mO mCnI-fyiU)CA nfy2C0tWm*OnaX n-10(A23Attachment IIN 91-25April 1, 1991Page I of 1InformaticNotice No.I-491-2491-23onLIST OF RECENTLY ISSUEDNRC INFORMATION NOTICESDate of91-2291-2191-2090-43,Supp. 191-1991-18SubjectRecent Operating ExperienceInvolving Reactor OperationWithout A Licensed ReactorOperator or Senior ReactorOperator Present in theControl RoomAccidental Radiation Over-exposures to Personnel Due toIndustrial Radiography Acces-sory Equipment MalfunctionsFour Plant Outage Events In-volving Loss of AC Power orCoolant SpillsInadequate Quality AssuranceProgram of Vendor SupplyingSafety-Related EquipmentElectrical Wire InsulationDegradation Caused Failure inA Safety-Related MotorControl CenterMechanical Interference withThermal Trip Function in GEMolded-Case Circuit BreakersSteam Generator FeedwaterDistribution Piping DamageHigh-Energy Piping FailuresCaused by Wall ThinningIssuance Issued to03/26/91 All holders of OLs orCPs for nuclear power,test, and research re-actors, and all Part 55licensed operators.03/26/91 All Nuclear RegulatoryConmission (NRC) licens-ees authorized to usesealed sources for indus-trial radiography.03/19/91 All holders of OLs orCPs for nuclear powerreactors.03/19/91 All holders of OLs orCPs for nuclear powerreactors and allrecipients of NUREG-0040,"Licensee Contractor andVendor Inspection StatusReportm (White Book).03/19/91 All holders of OLs orCPs for nuclear powerreactors.03/13/91 All holders of OLs orCPs for nuclear powerreactors.03/12/91 All holders of OLs orCPs for pressurizedwater reactors (PWRs).03/12/91 All holders of OLs orCPs for nuclear powerreactors.C(2AOL 0 Operating LicenseCP = Construction Permit IN 91-25April 1, 1991 Discussion:UC manufactures structural framing components used to support nonsafety andsafety-related components such as pipes, instrument lines, ducts, cable trays,and conduits. The NRC has not identified a significant safety concern orin-service failure regarding the known applications of these structural framingcomponents. However, structural framing components were supplied by UC assafety-related and may be installed in safety-related structures, systems, orcomponents and may not meet quality standards commensurate with the importanceof the safety function to be performed. Therefore, licensees may wish toreview their use of structural framing components to confirm that the procuredequipment is acceptable. In addition, licensees may wish to examine theadequacy of applicable audits and their audit process.This information notice requires no specific action or written response. Ifyou have any questions about this matter, please contact one of the technicalcontacts listed below or the appropriate KRR project manager.Charles E. Rossi, DirectorDivision of Operational Events AssessmentOffice of Nuclear Reactor RegulationTechnical Contacts: Steven M. Matthews, NRR(301) 492-3191Stewart L. Magruder, NRR(301) 492-3220

Attachment:

List of Recently Issued NRC Information Notices*SEE PREVIOUS CONCURRENCEOFC :Tech Ed :RVIB:NRR :RVIB:NRR :D:DRIS:NRR:OI : OE :__ ---------- _-----_----:----------:_----------:------- :------NAME:*JMain :*SMatthews:*UPotapovs:*BKGrimes :*BW :*ETB :_- --- ----_ _ _ __ __-:_--__-___-----:---------:----:--: ------DATE:3/19/91 :3/21/91 :3/25/91 :3/25/91 :3/26/91:3/26/91:OFC :OGC :OGCB:DOEA:NRR:D:DOEA:NRRNAME:*RHoefling :*CHBerlinger : RDATE: 3/26/91 :3/26/91 :3W/91OFFICIAL RECORD COPYDOCUMENT NAME: UNISTRUT INFORMATION NOTICE/JL v)IN 91-XXXMarch 25, 1991 UNISTRUT INFORMATION NOTICE(*) SEE PREVIOUS CONCURRENCEOFC :ADM/DFIPS :SMMatthews:UPotapovs:BK Ii s : Ir :OE____ --------- ------NAME:JMain :: Ar:___-______________- --------- -------:::DATE: 3/19/91* : 3/21/91*: 3/ D /91: 3/2,/91 : 9 :3/2G/91:3/;X'/91:/ # AOFC : OGC : CHBerlinger:CMRossiNAME: l**DATE: _ _ : 3------------:---- -:DATE: 3/2,4/91 \: 3/ *91,: :

IN 91-XXXPage 4xUNISTRUT INFORMATION NOTICE(*) SEE PREVIOUS CONCURRENCEOFC :ADM/DFIPS :SMMatthews:UPotapovs:BKGri s : OI : OE____- -_ _ _ ,_ ---------:- ---------*---------NAME:JMain : 7 F :____ ___________ _------ --------- -f----- ------- ----DATE: 3/19/91* : 3/4 /91 : 3/ /91 : / /91 :3/ /91:3/ /91:OFC :CHBerlinger:CHRossi :/____ ___--------: -------NAME::: /____ __-------- ---- ----DATE: 3/ /91 :3/ /91 :/

iIN 91-XMarch XIX, 1991of X

Attachments:

1. List of Recently Issued NRC InformationOFC :TECH EDITOR:SMMatthews:UPotapOvS:B rimes : OI : OENAME: JM3in 9 : /DATE: 3S/l/91 : 3/ /91 : 3 /91 : 3/ /91 :3/ /91:3/ /91:OFC :CHBerlinger:CHRossi____ ________---- ------NAME:DATE 3___1__---- --/ :DATE: 3X /91 :/X /91 :