ML18053A553
| ML18053A553 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 09/01/1988 |
| From: | Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| IEB-88-005, IEB-88-5, NUDOCS 8809080047 | |
| Download: ML18053A553 (11) | |
Text
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POW ERi Nii
/llllCHlliAN'S. PROliRESS General Offices:
1945 West Parnall Road. Jackson, Ml 49201 * (517) 788-1636 September 1, 1988 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
NRC BULLETIN NO. 88-05 RESPONSE - NONCONFORMING MATERIALS Kenneth W Berry Director Nuclear Licensing NRC Bulletin No. 88-05, dated May 6, 1988, required a 120 day report on requested actions.
Supplement 1 to the bulletin, dated June 15, 1988, provided further direction and information.
Supplement 2 to the bulletin, issued on August 3, 1988, temporarily suspended requirements to complete records searching and testing.
This letter provides the requested response.
It includes a summary of all actions taken to date and planned actions remaining to complete the bulletin.
I.
The bulletin and supplement 1 requested the following actions:
- a.
Promptly review purchasing records to determine whether any ASME Code or ASTM fittings and flanges were furnished by Piping Supplies, Incorporated (PSI) and West Jersey Manufacturing (WJM).
WJM records should cover the period since January 1, 1976.
- b.
For items not yet installed, provide a listing of those found not to be in conformance with requirements and identify the applications that the items will be used in.
The listing should include the material specification, type of item, size, pressure rating, chain of purchase and results of all tests.
- c.
For items not yet installed, take actions that provide assurance they comply with ASME Section III, ASTM, and applicable procurement requirements or that demonstrate that such materials are suitable for the intended service.
Replace all questionable fittings and flanges.
- d.
For items already installed in safety related systems, provide a listing of those found not to be in conformance with requirements and identify the application.
The listing should include the material specification, type of item, size, pressure rating, chain of purchase, and results of all tests.
OC0888-0107-NL02 gon9noon47 880901
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Nuclear Regulatory Commission Palisades Nuclear Plant NRC Bulletin No. 88-05 Response September 1, 1988 2
- e.
For items already installed in safety related systems, take actions that provide assurance they comply with ASME Section III, ASTM, and applicable procurement requirements, or that demonstrate that such materials are suitable for the intended service.
Test accessible items, compare test results to specifications and to values list~d on CMTRs, and perform an analysis justifying continued operation if there are any deviations. If items are inaccessible, perform an analysis justifying continued operation.
Perform the testing and/or analyses within 30 days of identification.
Replace all questionable fittings and flanges, taking expected radiation exposures into account when planning the method and timing of replacements.
- f.
Document a basis for continued plant operation if the assessment of items installed in safety related systems are not completed within 120 days of the receipt of the bulletin.
- g.
Report test results to the INPO Nuclear Network for dissemination to the industry.
- h.
Report any need to justify continued operation to the NRC within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.
- i.
For items having suspect CMTRs and used in non-safety-related systems, take actions commensurate with the function of the item.
- j. Retain nonconforming items until advised further by the NRC.
Segregate them to preclude inadvertent use.
- k.
Maintain documentation of specific actions taken.
- 1.
Complete all planned actions before restarting from the next major outage starting after 180 days from the date of receipt of the bulletin.
- m.
Provide a written report within 120 days of receipt of the bulletin.
The report should provide the information on what items were not yet installed, along with those installed in safety related system, when such items were found not to be in conformance with requirements.
The report should also confirm completion of actions to assure uninstalled items comply with requirements or are replaced, confirm completion of actions to assure items installed in safety related systems comply with requirements or are replaced, confirm completion of actions taken for items with suspect CMTRs installed in non-safety-related systems.
The report should also provide a schedule for completing any remaining actions.
- n.
Confirm completion of all scheduled actions to the NRC within 60 days of completion.
OC0888-0107-NL02
Nuclear Regulatory Commission Palisades Nuclear Plant NRC Bulletin No. 88-05 Response September 1, 1988 II. Actions taken to date, correlating to the action requested above, are:
- a.
Records of all pipe and piping supplies were reviewed for items which were obtained directly or indirectly from PSI and WJM over the requested time periods.
Receiving inspection logs were used to determine which items were obtained via plant procurements.
Project modification records packages were reviewed to determine those items obtained more indirectly from contractors.
3 A total of 112 flanges had been obtained, all from WJM.
No items other than flanges were obtained from WJM and no items were found from PSI.
A list of purchase orders and the items obtained is in.
Most of the flanges had been obtained from Chicago Tube and Iron.
A June 15, 1988 letter from them reported the results of their records search, correlating with those found at Palisades.
Another effort further substantiated our results, a physical search of the warehouse storage locations for flanges.
- b.
Reviews of warehouse issue records, along with physical verifications of warehouse storage areas and accessible installations, were performed.
76 of the 112 flanges were in warehouse bins, not yet installed.
Since these flanges were still in stock their application has not been determined.
All 76 flanges were tested for hardness using a portable Equotip hardness tester.
6 of the flanges were found to be below the 398 Leeb value (137 Brinell) and 2 were found to be above 463 Leeb units (187 Brinell). Attachment 3 provides the specific information requested by the bulletin.
The practice of Palisades is to purchase stock flanges as safety related and use them in both safety related and non-safety related applications.
No WJM or PSI non-safety related items were found in the warehouse.
If any were ever ordered, they would not have been supplied with CMTRs nor would the CMTRs have been relied on.
- c.
Nonconforming Material Reports (NMRs) were issued to control the uninstalled flanges.
They were moved from warehouse bins into the receipt inspection hold area and hold tags affixed.
The NMRs for the 8 flanges found out of specification have not yet been dispositioned.
The 6 flanges with low hardness values will be dispositioned following completion of generic industry or NRC guidance.
The two flanges with high hardness values are not being generically evaluated and will remain in hold for the present.
Other of the tested flanges may be dispositioned on a~ as needed basis.
OC0888-0107-NL02
Nuclear Regulatory Commission Palisades Nuclear Plant NRC Bulletin No. 88-05 Response.
September 1, 1988 4
- d.
A total of eight flanges in safety related applications have been identified.
Five flanges installed in safety related applications have been hardness tested to date.
None were found out of specifi-cation.
Three other flanges identified in safety related applications are inaccessible during power operation and have not been tested to date.
- e.
Hardness testing data (Leeb numbers from Equotip tester) was converted to Brinell hardness numbers using Table 2-1 of EPRI NP-5769, Volume 2.
The hardness testing data was compared to the range of acceptable Brinell hardness given in ASME SA-105, 137 to 187.
The hardness readings of each heat were also correlated with the carbon contents reported by the CMTRs received with the flanges.
On a relative basis, lower hardness readings correlated with lower carbon content and higher hardness readings with higher carbon content.
None of the CMTRs appeared to be 'suspect'.
Three flanges identified in safety related applications were inaccessible.
A justification for continued operation (JCO) was prepared and documented and is available at Palisades.
- f.
The testing of the 5 installed flanges and the JCO for the 3 inaccessible ones were completed by 07/18/88, within the 120 days required by the bulletin.
- g.
A summary of test results was sent to the NUMARC specified point of contact, on July 19, 1988.
More detailed information was provided on August 19, 1988 to the industry database being developed by NUMARC/Bechtel.
- h.
The need for the JCO for the 3 inaccessible flanges was reported to the NRC by telecon on 7/1/88, within the 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> specified in the bulletin.
- i.
In addition to the 8 flanges installed in safety related applications, there is one flange installed in a non-safety related application.
It is currently being treated consistent with the safety related installations.
Plans were to complete hardness testing during the current refueling outage.
- j. The 8 not yet installed flanges with hardness readings outside the SA-105 tolerance band are being held in the receipt inspection hold area, with NMRs issued on them.
Presently there are no other special controls being applied to the untested installed flanges.
- k.
Documentation of actions taken to date is being held at Palisades until further information is received.
OC0888-0107-NL02
Nuclear Regulatory Commission Palisades Nuclear Plant NRC Bulletin No. 88-05 Response September 1, 1988
- 1.
The date for completing all actions is currently indeterminate due to supplement 2 to the bulletin, temporarily suspending actions being taken.
- m.
This letter provides all information requested by the bulletin except for the schedule for completing remaining actions.
Information specifically requested for the 120 day report is:
- 1)
A list of items found not to be in conformance with requirements (Attachment 2)
- 2)
Confirmation that actions are taken to preclude use of uninstalled nonconforming items (controlled by NMRs per paragraph II. j above).
5
- 3)
Confirmation that actions are taken to assure items installed in safety related applications are verified to be in conformance with requirements or are replaced.
The five installed flanges which were tested met hardness criteria (paragraphs II.d and II.e above)
- 4)
Confirmation that appropriate actions are taken for items installed in non-safety related applications (paragraph II.i above).
- n.
A final report will be prepared after all planned actions are completed.
Kenneth W Berry Director, Nuclear Licensing CC Administrator, Region III, NRC NRC Resident Inspector - Palisades Attachments OC0888-0107-NL02
CONSUMERS POWER COMPANY Palisades Plant Docket 50-255 - License DPR-20 RESPONSE TO NRC BULLETIN NO. 88-05 At the request of the Commission and pursuant to the Atomic Energy Act of 1954 and the Energy Reorganization Act of 1974, as amended, and the Commission's Rules and Regulations thereunder, Consumers Power Company submits our response to NRC Bulletin 88-05 dated 8/3/88, 6/15/88, 5/6/88, entitled, "Nonconforming Materials Supplied by Piping Supplies, Inc. at Folsom, New Jersey and West Jersey Manufacturing Company at Williamston, New Jersey," Consumers Power Company's response is dated September 1, 1988.
CONSUMERS POWER COMPANY David r sident Nuclear Operations Sworn and subscribed to before me this 1st day of September, 1988.
1~~&~
Elaine E Buehrer, Notary Public Jackson County, Michigan My commission expires October 31, 1989 OC0888-0107-NL02
OC0888-0107-NL02 ATTACHMENT 1 Consumers Power Company Palisades Plant Docket 50-255 FLANGES OBTAINED FROM WJM September 1, 1988 2 Pages
P.O.
P.O.
P.O.
Flanges Obtained From WJM 1004-8369Q to Chicago Tube and Iron 2 flanges, heat #6011375 1003-1173Q to Chicago Tube and Iron 2 flanges, heat #958 1005-39470 to Chicago Tube and Iron 4 flanges, heat #3718 (test code AA0-84)
Bechtel P.O. 12447-M99E(Q) AC to Capital Pipe and Steel 3 flanges, heat #CBL P.O.
P.O.
P.O.
P.O.
P.O.
P.O.
P.O.
P.O.
P.O.
P.O.
P.O.
5014-3609-QA to Chicago Tube and Iron 5 flanges, heat #18596 (test code CES) 1004-9194Q to Chicago Tube and Iron 5 flanges, heat # CFB 1005-0984Q to Chicago Tube and Iron 3 flanges, heat #23832 (test code CFV) 1005-0092Q to Chicago Tube and Iron 6 flanges, heat # 1533/test code CFW) 5010-2155-QA to Chicago Tube and Iron 6 flanges, heat #1533 (test code CFW) 1005-2238Q to Chicago Tube and Iron 4 flanges, heat #8602 (test code CFY) 1004-2511Q to Chicago Tube and Iron 4 flanges, heat #8602 (test code CFY) 1005-0832Q to Chicago Tube and Iron 4 flanges, heat # 7416 (test code CHV) 5014-3232-QA to Chicago Tube and Iron 4 flanges, heat #3095 (test code CIW) 1005-4658Q to Chicago Tube and Iron 5 flanges, heat #3095 (test code CIW) 1006-1021Q to Chicago Tube and Iron 20 flanges, heat #2835 (test code CKS) 20 flanges, heat #2903 (test code AAY-84)
OC0888-0107-NL02 Page 1 of 2 P.O. Issue Date 07/27/83 12/11/81 02/27/84 10/24/83 04/24/85 08/31/83 11/02/83 09/30/83 09/06/83 12/19/83 01/10/83 10/26/83 04/17/85 03/16/84 01/16/85
P.O.
5012-4536QA to Chicago Tube and Iron 4 flanges, heat #25315 (test code COL)
P.O.
1005-6836Q to Chicago Tube and Iron 4 flanges, heat #25315 (test code COL)
Bechtel P.O.
12447-M99E~(Q)- AC to Capital Pipe and Steel 1 flange, heat #T8852 (heat code GDIE)
P.O. 1003-8833Q to Chicago Tube and Iron 4 flanges, heat #N85482 (heat code GDDU)
P.O. 1004-0639Q to Chicago Tube and Iron 2 flanges, heat #N77481 (heat code GDLD)
TOTALS - 20 purchase orders 112 flanges OC0888-0107-NL02 Page 2 of 2 07/11/84 05/11/84 06/01/83 09/01/82 11/01/82
OC0888-0107-NL02 ATTACHMENT 2 Consumers Power Company Palisades Plant Docket 50-255 FLANGES FOUND NOT TO BE IN CONFORMANCE WITH REQUIREMENTS September 1, 1988 1 Page
Flanges Found Not to be in Conformance With Requirements Heat #1533 (test code CFW) - 1 of 12 flanges tested (from P.O. 1005-0092) had a Leeb hardness of 396, correlating to a Brinell hardness of 136.
- SA105, 2
11, 600 lb.
Heat #3095 (test code CIW) - 3 of 5 flanges tested (all 3 from P.O. 1005-4658)
.were Leeb hardnesses of 373, 379 and 380, correlating to Brinell hardness readings of 120, 124 and 125.
SA105, 1 11
, 150 lb.
Heat 11 25315 (test code COL) - 1 of 5 flanges tested (from P.O.* 1005-6836) had a Leeb reading of 466, correlating to a Brinell hardness of 190, SA105, 2", 150 lb.
Heat #CFB - 2 of 4 flanges tested had Leeb readings of 385 and 392, correlating to Brinell readings of 128 and 133.
SA105, 3/4", 150 lb.
Heat #N85482 (test code GDDU) - 1 of 3 flanges tested had a Leeb reading of 482, correlating to a Brinell reading of 204.
- SA105, l~", 300 lb.
NOTE:
all except the first item are blind flanges OC0888-0107-NL02