Information Notice 1991-25, Commercial-Grade Structural Framing Components Supplied as Nuclear Safety-Related Equipment
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
WASHINGTON, D.C.
20555
April 1, 1991
NRC INFORMATION NOTICE NO. 91-25: COMMERCIAL-GRADE STRUCTURAL FRAMING
COMPONENTS SUPPLIED AS NUCLEAR
SAFETY-RELATED EQUIPMENT
Addressees
All holders of operating licenses or construction permits for nuclear power
reactors.
Purpose
This information notice is intended to alert licensees to problems in the
dedication of structural framing components supplied to the nuclear industry by
the Unistrut Corporation (UC), Wayne, Michigan. It is expected that recipients
will review this information for applicability to their facilities and consider
actions, as appropriate, to avoid similar problems.
However, suggestions
contained 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 are
1-5/8-inch wide, continuously slotted, structural framing channel members;
fasteners; and mechanical accessories such as channel nuts, fittings, and pipe
clamps.
These components are supplied through a network of nationwide
Authorized 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 to
implement measures to control the dedication of commercial-grade structural
framing components. UC supplied Certificates of Conformances (COCs) stating
that these materials met the requirements of Appendix B to Part 50 of Title 10
of the Code of Federal Regulations (10 CFR) and were supplied in accordance
with the provisions of 10 CFR Part 21.
UC failed to demonstrate that it had:
(1) established an adequate basis for accepting material certifications from
its suppliers of fasteners and coil material, (2) verified the chemical and
physical properties of coil material, (3) performed destructive product testing
traceable to each coil of material used to manufacture structural framing
channel, (4) maintained traceability of the material used to manufacture
mechanical accessories, or (5) performed adequate product testing on all
mechanical accessories.
UC manufactures structural framing channel members from coil material procured
to UC's material specifications from various commercial-grade suppliers and
manufacturers. These suppliers provided material certifications that UC
g 27O3O4 4
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IN 91-25 April 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 on
structural framing channel that was traceable to each heat or lot of coil
material.
Furthermore, UC did not perform tests or examinations to ensure the
accuracy of the chemical and physical properties listed in the material certi- fications.
UC supplied the commercial-grade structural framing channel to
licensees as safety-related components that comply with the requirements of the
American Society for Testing and Materials (ASTM) Standards, Appendix B to
10 CFR Part 50, and 10 CFR Part 21 with COCs stating that these requirements
were met, even though UC did not perform an adequate commercial-grade dedication
of the coil material. In some instances, UC also certified that the channel
met the requirements of the American Society of Mechanical Engineers, Boiler
and Pressure Vessel Code (ASME Code),Section III, Class 2, Subsection NF-2600
but did not demonstrate compliance with the ASME Code requirements.
All fasteners supplied by UC were procured as commercial-grade items from a
single supplier (General Fastener Company of Livonia, Michigan), which furnished
machine screws, nuts, and washers that were 1/2-inch and smaller. UC procured
these fasteners according to the Society of Automotive Engineers (SAE) Standards
and supplied them to licensees as safety-related fasteners that comply with the
requirements of the ASTM Standards, Appendix B to 10 CFR Part 50, and
10 CFR Part 21 with COCs stating these requirements were met, even though UC did
not perform any commercial-grade dedication activities.
Mechanical-accessories -are -alsormanufactured by UC-from coil material procured
to UC's material specifications from various commercial-grade suppliers and
manufacturers.
These suppliers provided material certifications that UC
accepted without assuring that the coil materials could be traced and identified
to the certifications.
Channel nuts and 90-degree angle fittings are the
only mechanical accessories that receive product tests. UC also did not
perform tests or examinations to ensure the accuracy of the chemical and
physical properties listed in the material certifications. UC supplied the
mechanical accessories to licensees as safety-related components that comply
with the requirements of ASTM Standards, Appendix B to 10 CFR Part 50, and
10 CFR Part 21 with COCs stating these requirements were met, even though UC
did not perform an adequate commercial-grade dedication of the coil material.
Licensees have conducted numerous audits of UC and some have placed UC on
their approved vendor lists to supply safety-related components. The inspectors
examined sample audit conclusions and found that they varied widely. Some
licensees found that UC was fully capable of supplying safety-related components
that comply with the requirements of Appendix B to 10 CFR Part 50 and
10 CFR Part 21, and in one instance found that UC could supply safety-related
components that comply with.the ASME Code requirements. Other licensees found
that UC could only supply commercial-grade components. In performing many of
the audits, licensees did'not identify UC's failure to implement adequate
measures to control the dedication of commercial-grade structural framing
components, indicating a significant weakness in the performance of these
audits.
IN 91-25 April 1, 1991 Discussion:
UC manufactures structural framing components used to support nonsafety and
safety-related components such as pipes, instrument lines, ducts, cable trays, and conduits. The NRC has not identified a significant safety concern or
in-service failure regarding the known applications of these structural framing
components.
However, structural framing components were supplied by UC as
safety-related and may be installed in safety-related structures, systems, or
components and may not meet quality standards commensurate with the importance
of the safety function to be performed. Therefore, licensees may wish to
review their use of structural framing components to confirm that the procured
equipment is acceptable. In addition, licensees may wish to examine the
adequacy of applicable audits and their audit process.
This information notice requires no specific action or written response. If
you have any questions about this matter, please contact one of the technical
contacts listed below or the appropriate NRR project manager.
Directo~r
Division of Operational Events Assessment
Office of Nu-clear Reactor-Regulation
Technical Contacts: Steven M. Matthews, NRR
(301) 492-3191
Stewart L. Magruder, NRR
(301) 492-3220
Attachment: List of Recently Issued NRC Information Notices
2
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Attachment I
April 1, 1991
Page I of 1 Informatic
Notice No.
I-4
91-24
91-23 on
LIST OF RECENTLY ISSUED
NRC INFORMATION NOTICES
Date of
91-22
91-21
91-20
90-43, Supp. 1
91-19
91-18 Subject
Recent Operating Experience
Involving Reactor Operation
Without A Licensed Reactor
Operator or Senior Reactor
Operator Present in the
Control Room
Accidental Radiation Over- exposures to Personnel Due to
Industrial Radiography Acces- sory Equipment Malfunctions
Four Plant Outage Events In- volving Loss of AC Power or
Coolant Spills
Inadequate Quality Assurance
Program of Vendor Supplying
Safety-Related Equipment
Electrical Wire Insulation
Degradation Caused Failure in
A Safety-Related Motor
Control Center
Mechanical Interference with
Thermal Trip Function in GE
Molded-Case Circuit Breakers
Steam Generator Feedwater
Distribution Piping Damage
High-Energy Piping Failures
Caused by Wall Thinning
Issuance
Issued to
03/26/91
All holders of OLs or
CPs for nuclear power, test, and research re- actors, and all Part 55 licensed operators.
03/26/91
All Nuclear Regulatory
Conmission (NRC) licens- ees authorized to use
sealed sources for indus- trial radiography.
03/19/91
All holders of OLs or
CPs for nuclear power
reactors.
03/19/91
All holders of OLs or
CPs for nuclear power
reactors and all
recipients of NUREG-0040,
"Licensee Contractor and
Vendor Inspection Status
Reportm (White Book).
03/19/91
All holders of OLs or
CPs for nuclear power
reactors.
03/13/91
All holders of OLs or
CPs for nuclear power
reactors.
03/12/91
All holders of OLs or
CPs for pressurized
water reactors (PWRs).
03/12/91
All holders of OLs or
CPs for nuclear power
reactors.
C
(
2 A
0
Operating License
CP = Construction Permit
IN 91-25 April 1, 1991 Discussion:
UC manufactures structural framing components used to support nonsafety and
safety-related components such as pipes, instrument lines, ducts, cable trays, and conduits. The NRC has not identified a significant safety concern or
in-service failure regarding the known applications of these structural framing
components. However, structural framing components were supplied by UC as
safety-related and may be installed in safety-related structures, systems, or
components and may not meet quality standards commensurate with the importance
of the safety function to be performed.
Therefore, licensees may wish to
review their use of structural framing components to confirm that the procured
equipment is acceptable. In addition, licensees may wish to examine the
adequacy of applicable audits and their audit process.
This information notice requires no specific action or written response.
If
you have any questions about this matter, please contact one of the technical
contacts listed below or the appropriate KRR project manager.
Charles E. Rossi, Director
Division of Operational Events Assessment
Office of Nuclear Reactor Regulation
Technical Contacts:
Steven M. Matthews, NRR
(301) 492-3191
Stewart L. Magruder, NRR
(301) 492-3220
Attachment:
List of Recently Issued NRC Information Notices
- SEE PREVIOUS CONCURRENCE
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OFFICIAL RECORD COPY
DOCUMENT NAME: UNISTRUT INFORMATION NOTICE/JL
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IN 91-XXX
March 25, 1991 UNISTRUT INFORMATION NOTICE
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SEE PREVIOUS CONCURRENCE
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Attachments:
1. List of Recently Issued NRC Information
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